Tribunal Criminal Tribunal for the Former Yugoslavia

Page 11577

 1                           Wednesday, 17 September 2014

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 9.02 a.m.

 5             JUDGE DELVOIE:  Good morning to everyone in and around the

 6     courtroom.

 7             Madam Registrar, could you call the case, please.

 8             THE REGISTRAR:  Good morning, Your Honours.  This is case

 9     IT-04-75-T, the Prosecutor versus Goran Hadzic.

10             JUDGE DELVOIE:  Thank you.

11             May we have the appearances, please, starting with the

12     Prosecution.

13             MR. STRINGER:  Good morning, Mr. President, Your Honour,

14     Judge Hall.  For the Prosecution, Douglas Stringer, Alexis Demirdjian,

15     Thomas Laugel, legal intern, Ljubica Vukcevic.

16             JUDGE DELVOIE:  Thank you.

17             Mr. Zivanovic, for the Defence.

18             MR. ZIVANOVIC:  Good morning, Your Honours.  For the Defence of

19     Goran Hadzic, Zoran Zivanovic and Christopher Gosnell.

20             JUDGE DELVOIE:  Thank you.

21             We were told there were some administrative matters.

22             Mr. Stringer.

23             MR. STRINGER:  Yes, thank you, Mr. President.

24             We had a question about scheduling for next week.  We noticed

25     that on the witness schedules that were distributed last Thursday by the

Page 11578

 1     Defence, we have DGH-010 on for Wednesday and Thursday of next week.  And

 2     it seems somewhat ambitious in that there is a pending videolink motion

 3     for that witness that still has not been ruled on.  And so we're

 4     wondering whether we do, in fact, need to prepare to cross-examine this

 5     witness next week, and if not, who the witness would be that we would

 6     need to prepare for.

 7             JUDGE DELVOIE:  Mr. Zivanovic.

 8             MR. ZIVANOVIC:  Your Honours, it is one of issues that I also

 9     wanted to address to the Chamber.

10             Actually, we have, indeed, one problem with the next witnesses

11     because we have actually three group of witnesses.  One group of them is

12     waiting for videolink; one -- another group is waiting for safe conduct;

13     and the third group is waiting for transfer.

14             We -- at the moment, we know that four of the witnesses waiting

15     for the safe conduct, these are Witnesses DGH-009, DGH-011, DGH-016, and

16     DGH-107 --

17             JUDGE DELVOIE:  207 is?

18             MR. ZIVANOVIC:  107.

19             JUDGE DELVOIE:  100.

20             MR. ZIVANOVIC:  Sorry.

21             For the them, the Prosecution did not take position as to our

22     safe conduct motion, and we'll do our best to put them on the witness

23     list either -- it is too late maybe for the next week but for the week

24     after that.  For the week of 29 of September, I think, at least some of

25     them could be put on that list.

Page 11579

 1             And for this week, the next witness is the last witness for this

 2     week.  We were not able to -- for the next week, we have just two

 3     witnesses because I also think that the third witness isn't, and he's

 4     videolink, is technically impossible to provide in such short term.

 5             JUDGE DELVOIE:  Thank you.

 6             MR. ZIVANOVIC:  And I had one other issue, too.  It's related to

 7     the submission of Mr. Demirdjian yesterday.  It is a part -- it's related

 8     to one part of his submission.  It is at the page 573 through 574.  I'll

 9     cite it.

10             "Your Honours, yes.  It's, number one, to avoid such problems in

11     the future to have 92 ter statements in a more thorough fashion."

12             I don't know what kind of the future Mr. Demirdjian had on mind,

13     but I use this opportunity to say that all our Rule 92 ter statements

14     have been submitted, and we'll not prepare any other statement either in

15     more or less thorough manner.

16             I would also remind the Prosecution -- remind that the

17     Prosecution raised a similar objection in their response to our Rule 92

18     ter statements for this particular witness and the motion was granted.

19     In short, the Defence will comply with the Trial Chamber's decisions in

20     respect of Rule 92 ter statements but could not comply with the ambitious

21     request from the Prosecution.  Thank you.

22             JUDGE DELVOIE:  Thank you, Mr. Zivanovic.

23             We will come back with regard to the scheduling issues probably

24     right after the first break.

25             The witness may be brought in.


Page 11580

 1                           [The witness entered court]

 2             JUDGE DELVOIE:  Good morning, Mr. Witness.

 3             THE WITNESS: [Interpretation] Good morning.

 4             JUDGE DELVOIE:  Thank you for coming to The Hague to assist the

 5     Tribunal.  First of all, do you hear me in a language you understand?

 6             THE WITNESS: [Interpretation] Yes, I can hear you.

 7             JUDGE DELVOIE:  Thank you.

 8             Could you give us your name and date of birth, please.

 9             THE WITNESS: [Interpretation] My name is Milenko Dafinic.  I was

10     born on the 2nd of September, 1958.

11             JUDGE DELVOIE:  Thank you.  Mr. Dafinic, you are to make -- you

12     are about to make the solemn declaration by which witnesses declare to

13     tell -- commit themselves to tell the truth.  I must point out to you

14     that by doing so, you expose yourself to the penalty of perjury should

15     you give untruthful or false information.  Could I ask you to make the

16     solemn declaration now the court usher will give to you.

17                           WITNESS:  MILENKO DAFINIC

18                           [Witness answered via interpretation]

19             THE WITNESS: [Interpretation] I solemnly declare that I will

20     speak the truth, the whole truth, and nothing but the truth.

21             JUDGE DELVOIE:  Thank you very much.  You may be seated.

22             Whose witness -- Mr. Zivanovic?

23             MR. ZIVANOVIC:  Yes, Your Honour.  Thank you.

24             JUDGE DELVOIE:  Thank you.

25             MR. ZIVANOVIC:  Mr. President, with your permission, I would


Page 11581

 1     provide the witness with his witness statement.

 2             JUDGE DELVOIE:  Go ahead.

 3                           Examination by Mr. Zivanovic:

 4        Q.   [Interpretation] Good morning, Mr. Dafinic.

 5        A.   Good morning.

 6        Q.   Although the two of us have already met, I will introduce myself

 7     for the record.  My name is Zoran Zivanovic, and I represent Goran Hadzic

 8     in these proceedings.

 9             Mr. Dafinic, before you, you have your statement.

10             MR. ZIVANOVIC: [Interpretation] 1D2859.

11        Q.   While we are waiting for the document to appear on the screen, I

12     would kindly ask you to look at all the pages in the statement and

13     ascertain that they have all been signed by yourself.

14        A.   Yes.

15             JUDGE DELVOIE:  Mr. Zivanovic, I see on your witness list that

16     the statement is to be used under seal.

17             MR. ZIVANOVIC:  No.

18             JUDGE DELVOIE:  No.

19             MR. ZIVANOVIC:  No, no.

20             JUDGE DELVOIE:  Okay.

21             MR. ZIVANOVIC:  1D28 -- ah, okay.  It's here.

22        Q.   [Interpretation] You had an opportunity to look at your statement

23     and review it.  Did you ascertain that your signature is on the bottom of

24     every page?

25        A.   Yes, I did.

Page 11582

 1        Q.   After your arrival in The Hague, we met on three occasions, and

 2     on those occasions you have provided me with some explanations of the

 3     statement.  Please look at paragraph 2 in your statement.  In that part,

 4     you spoke about the arrest of Goran Hadzic and Borivoje Savic at Plitvice

 5     in 1991 and on the erection of barricades in Borovo Selo.  Were there any

 6     talks about the removal of those barricades?  If so, who was involved in

 7     those talks?

 8        A.   Yes, there were talks about removing the barricades involving

 9     Vukasin Soskocanin and Marko Loncarevic, and that was conditional on the

10     release of Goran Hadzic and Boro.  They said that in that case the

11     barricades would be removed.

12        Q.   And who did they talk to?  Could you please tell us?  I mean

13     Soskocanin and --

14        A.   As far as I know, they went to Sarvas or to Aljmas, and I think

15     that they spoke to Kir from Osijek, who was either the chief of police or

16     something else.  Kir, Josip Kir, Kir, Kir.  In any case, he was from

17     Osijek.

18        Q.   In paragraph 3, you said that you couldn't say that Soskocanin

19     was the commander of village guards in Borovo Selo.  And can you please

20     tell us what was his relationship with those guards?

21        A.   Well, I can put it this way:  Everybody knew him.  And he was

22     held in high esteem.  People respected him and listened to him.  He was

23     more like a co-ordinator, not commander.  People came to him to ask for

24     advice.  He co-ordinated them.  He told some of them to go in the

25     direction of Dalj and Savulje, the others to Crepulja, the third group

Page 11583

 1     was sent to the railway, and so on and so forth.

 2        Q.   In paragraph 4 you said, inter alia, that Soskocanin received

 3     weapons.  How did you know that?  How did you learn that?

 4        A.   I was very good friends with Soskocanin.  Actually, he was my

 5     best man.  He trusted me.  He told me that he had brought weapons, and he

 6     asked me whether I would like to join them and to take weapons.  The

 7     situation was as it was.  I accepted that wholeheartedly.  He gave me an

 8     old Thompson which I couldn't even handle.  I needed to be explained how

 9     to use that weapon.  It was an old automatic rifle or something like

10     that.

11        Q.   When you say that the situation was what it was, could you please

12     explain.  What was the situation like at the time when you accepted to

13     take the weapon that was offered to you?

14        A.   The situation was rather tense.  At that time, I was fired from

15     work.  I was made redundant.  But that was based on my Serb ethnicity.

16             We withdrew and we -- and they put chequer-boards on their caps

17     instead of five-pointed stars.  We were not happy with that.  We were

18     against that symbol, the symbol of the chequer-board.  We wanted them to

19     sport five-pointed stars on their police caps.  Those were Yugoslav

20     symbols and we were in favour of Yugoslavia.

21        Q.   And I understand your position.  And why did you accept the

22     rifle?  Did you feel threatened?

23        A.   Yes.  We all took weapons because on one occasion a group of us

24     gathered.  It was an SDS gathering, and they came with weapons to dispel

25     our gathering.  There were some 20 or 30 police officers and an incident

Page 11584

 1     ensued.  Truth be told, they didn't open fire on us or, vice versa, we

 2     didn't open fire on them.  However, there was lot of shoving and pushing.

 3     We almost got into a physical fight.  Bullets were fired into the air but

 4     nobody was injured.  I suppose that they just wanted to intimidate us.

 5        Q.   In paragraph 6, it is stated that the school was about 500 metres

 6     away from the centre of the village.  I believe that you wanted to

 7     correct something there.  What is the distance between the school and the

 8     centre?

 9        A.   The Bozidar Maslaric elementary school and the Cadjava Mahana

10     cafe, the distance is about 200 to 250 metres.  The length of a football

11     pitch.  It is not 500 metres.  There are two streams between them, each

12     of them 100 metres.  So the distance between the school and the centre of

13     the village, the local commune building or the Cadjava Mahana cafe was

14     about 200 metres.

15        Q.   In paragraph 7, you described an incident which happened in

16     Borovo Selo on the 1st of May when two Croatian police officers were

17     captured because they wanted to remove the flag that was hoisted there on

18     the 1st of May which was a bank holiday.  You said that the two them were

19     taken way by Stevo Bogic who handed them over to the local police in

20     Novi Sad.  Did he do it on his own?  Was he alone when he took those two

21     men away or did somebody else go with him?  Could you please describe the

22     situation.

23        A.   A correction.  On the 1st of May, they wanted to remove that

24     flag -- or, rather, on the eve of the 1st of May.  And Stevo Bogic told

25     me that he did not transport them himself.  It was Veselko Petricevic who

Page 11585

 1     did that.  He was the son of a fisherman.  And also Dragan Gacic

 2     transported them.  Petricevic had a car, a Opal car, which he parked on

 3     the Serbian side.  However, they did not transport them in the car but by

 4     boats.  That's what I was told.

 5             Milenko Lazarevic, also known as Suljo, was also there.  And he

 6     told me that they then transported them by cars, they had weapons, and

 7     then somewhere around the village of Futog as they were entering Novi

 8     Sad, they were stopped by a police patrol.  They said that they had two

 9     wounded police officers in the car.  According to them, they did not

10     believe that until they approached the car and then they took them to the

11     police station.  And Stevo Bogic complained to me that he had to spend as

12     much three hours at the Novi Sad SUP when his statement was being taken.

13     That's what he told me.  And that same story was shared by Suljo

14     Lazarevic or Milenko Lazarevic.

15        Q.   In paragraph 9, you state that the Danube crossing was controlled

16     by Serbian police.  Was somebody in charge of that police team that

17     controlled the border crossing from Borovo Selo to the Serbian side?

18        A.   Yes, I can tell you that.  At that time the Serbian people were

19     in a state of panic.  The women and the children were particularly afraid

20     and started fleeing and finding shelter with their relatives and

21     acquaintances.

22             I also crossed the border, and on the other side, I met a man

23     whose name was Nenad Bogunovic, aka Neso.  He controlled the situation

24     very well.  He controlled the people who were crossing.  On the way back,

25     he again controlled us.  He wanted to know who we were before he could

Page 11586

 1     let us go.  He did not allow some people to cross.  I suppose that they

 2     were not either from Borovo Selo or any of the neighbouring villages.

 3     They came from Palaca, Vera, Trpinje.  All of them crossed across Borovo

 4     Selo and then they crossed the Danube to the other side.

 5             MR. DEMIRDJIAN:  I apologise for the interruption, Your Honours.

 6     Could we just have the name which was not recorded here.  At page 8,

 7     line 20, the witness says:

 8             "I have Veselko," he was the son of a fisherman.  The name hasn't

 9     been recorded.  If it's possible to have that name, please.

10             THE WITNESS: [Interpretation] His name was Okonja, he was a bar

11     owner.  Veselko Petricevic.  His family name was Petricevic, and his name

12     was Veselko.

13             MR. ZIVANOVIC: [Interpretation]

14        Q.   Mr. Dafinic, let's just correct the names because they have all

15     been misrecorded or not recorded at all.

16             First of all, let us repeat the names of those persons who,

17     together with Stevo Bogic, transported the police officers and handed

18     them over to the Novi Sad police.  You mentioned their names in

19     paragraph 7 in your statement.  What were their names?

20        A.   I said Stevo Bogic, Dragan Gacic, Veselin Petricevic, nicknamed

21     Okonja, O-k-o-n-j-a.  That was his father's nickname too which he

22     inherited.

23        Q.   Could we repeat the name of Dragan Gacic.  It was recorded as

24     Gagic.

25        A.   Yes, it is Gacic.

Page 11587

 1        Q.   And could you repeat the surname of Veselin.

 2        A.   The surname is Petricevic, nicknamed Okonja.

 3        Q.   You also mentioned some villages from which people came crossing

 4     the Danube and we miss also the name of the villages.

 5        A.   Trpinje, Bogota, Vera, Silas.  All those Serbian villages.  Also

 6     Palaca.  They came from all over the place.  There were not enough boats

 7     to carry all those people.

 8             MR. ZIVANOVIC:  I just think that Trpinja -- before Trpinja, it

 9     is the answer of the witness.  It is line 20.  It is written as part of

10     my question.

11             JUDGE DELVOIE:  Yes, indeed.  It will be corrected,

12     Mr. Zivanovic.  Thank you.

13             MR. ZIVANOVIC: [Interpretation]

14        Q.   In paragraph 11, you say your family were living as refugees in

15     Sabac.  Can you tell us more precisely, did they continuously live as

16     refugees in Sabac and until when?

17        A.   My family were staying with some relatives in Sabac.  I don't

18     know exactly how long.  It was a long time ago.  For seven or eight

19     months.  And I was beginning to think they were a burden to our relatives

20     so I moved them to Backa Palanka.  And my children who were in the

21     seventh and eighth grade enrolled in school there, and I moved them to

22     Backa Palanka so I could visit them more easily.  They were staying with

23     a man called Boca who had a restaurant and another man called Vojo who

24     was putting up two families.  They stayed there for two or three years,

25     coming back when the situation would calm down, and then when the

Page 11588

 1     shooting started again, they would go back.  I was afraid for my family,

 2     like everybody else.  There was also a camp in Delibarska Pescara where

 3     there were about 500 and some women and children, and they stayed for a

 4     while there too.

 5        Q.   In addition to your wife and children, did other women and

 6     children also leave Borovo Selo?

 7        A.   Yes, in large numbers.  There were not enough boats, so they

 8     found -- they established a ferry line where more people could cross at

 9     one time.  It was our only link to Serbia to go shopping for food.

10     People were then able to take their cars on the ferry and visit their

11     relatives in Serbia.  Some people went to big population centres, some

12     went to the country, to the country-side.

13        Q.   In paragraph 12, you said you knew well Vukasin Soskocanin, that

14     you had a Kum relationship.  That you were best men to each other?

15        A.   Yes.

16        Q.   How long did you know him?

17        A.   Soskocanin family had this Kum relationship with our family, the

18     Dafinic family, for generations.  Our grandfathers and great-grandfathers

19     were also in the same Kum relationship.  We were always best men to each

20     other.  You could say for a hundred years.

21        Q.   Did Soskocanin do his compulsory military service?

22        A.   No, he did not.  I know that.

23        Q.   What was his health like, if you know?

24        A.   He had some heart trouble.  He would take some pills under his

25     tongue.  I don't know what they're called.  Something like glycerin.

Page 11589

 1     That's probably why he didn't do his military service, although I never

 2     asked.  It's just my assumption.

 3        Q.   In paragraph 14, you say you participated in the fighting for

 4     Dalj.  Can you describe your participation?

 5        A.   I can.  Marko Loncarevic came to see me, and he is a native of

 6     Dalj.  And he said, "We are fed up with this ferry service and all these

 7     crossings.  We are going to organise an attack on Dalj so we can use the

 8     bridge," and asked me if I was willing to be part of his group.  And I

 9     answered why not.  Andric, Relja, was also in that group.  There were

10     also some two brothers, one of whom later got killed, Branko Marinovic,

11     the singer Alic.  I can't remember all the men.

12             Anyway, he took us along the Danube until we reached the first

13     houses.  We could only see the barking of dogs -- hear the barking of

14     dogs; we couldn't see anyone.  We reached a brook called Jama and he

15     deployed us there saying, "If the Ustashas come, the members of the ZNG,

16     the Croatian Home Guards, don't let them through.  Open fire."

17             After a short while he left us, and I didn't even see him

18     anymore.  We stayed there for a certain time.  I can't remember, an hour,

19     two, three, four hours, when we heard shooting from somewhere.  There was

20     no shooting from our side.  This brook, this canal, Jama, was near the

21     police station.  We couldn't across this brook because the water was

22     high.  And then I heard not a tank but an APC hit the police station.

23     There was very strong fire opened at the police station.

24             That's approximately all I saw there.  I didn't see that but I

25     heard that the policemen later surrendered, and they were loaded onto

Page 11590

 1     that APC, the fighting was over, there was no more shooting, and with

 2     that group that I had arrived with I turned back and went back to

 3     Borovo Selo.  It was already 11.00 or 12.00.  Borovo Selo was 7 to 8

 4     kilometres away.

 5        Q.   Could you clarify two points in this answer.  Did you see the

 6     projectile from the APC hit the police station or did you hear it?

 7        A.   We just heard and we saw the dust and smoke.  We only had

 8     infantry weapons.  So by the sound of that explosion, I supposed that it

 9     was a shell.  I was not close enough to see but there was a cloud of dust

10     and smoke, so I supposed that it must have been fired from a tank or an

11     APC or whatever.

12        Q.   Can you tell us from this river Jama, can you see the police

13     station?

14        A.   You can see through just a little bit.  You can't see all of it.

15        Q.   And when you said you returned around 11.00 or 12.00, are you

16     talking about a.m. or midnight?

17        A.   No, I'm talking about a.m. and noon.  If it was night-time, I

18     would have said 2200 hours or midnight.

19             When we first got there, we heard the noise of APCs.  The

20     shooting started only later.  But you know tanks and APCs are very noisy.

21     You can hear that, of course.

22        Q.   If you could please look at paragraph 16 now.  You say that you

23     were part of the security detail serving the government.

24        A.   At this place we called Dvorac mentioned.

25        Q.   And you said that on one occasion you did not let

Page 11591

 1     Radovan Stojicic, Badza, and Arkan enter the government headquarters

 2     armed.  Can you describe this occasion?  Was it one occasion when they --

 3     both them came together, or were these separate occasions?

 4        A.   Those were two separate occasions.  When we came to serve as

 5     guards to the government, I believe it was September, and just five or

 6     ten or maybe even 20 days later, that man came, introduced himself.  He

 7     said, "I am Radovan Stojicic, I want to get in."  I told him, "You can't

 8     get in carrying a weapon, and it's late, there is nobody left here."  He

 9     said, "There must be someone," and I replied, "We are security for the

10     government.  We would tell you if there was anyone inside."  So he drove

11     back in his Pajero jeep.

12             After a while, Zeljko Raznjatovic arrived but also very late at

13     night when there was nobody inside, and I told him the same as I had said

14     to Badza, "You cannot enter with your weapons, and whoever you are

15     looking for, they're not there.  You can come back tomorrow."  He just

16     turned back and left.  At that time I didn't even know it was Arkan.  And

17     he didn't say his name.  Stojicic did introduce himself.  Arkan did not

18     say anything.  He just wanted to get in.

19        Q.   Did you know when Radovan Stojicic introduced himself, did you

20     know who he was?  Had you seen him before that?

21        A.   No, I didn't know who he was.  Later I learned, but at that time

22     I didn't know.  At that time I didn't know all these people.  They were

23     all the same to me.

24        Q.   During our first interview, you showed me copies of some official

25     identity cards that you had; three copies to be precise.  Let us look at

Page 11592

 1     them now.

 2             MR. ZIVANOVIC: [Interpretation] 1D3429.

 3             THE WITNESS: [Interpretation] I see the copies.  It's better now

 4     that you enlarged it.

 5             MR. ZIVANOVIC: [Interpretation]

 6        Q.   Can you now look at the first one at the very top.  You've

 7     described it in paragraph 19.  Could you please look at paragraph 19 in

 8     your statement -- in your copy of the statement.  Is this the ID that you

 9     mentioned in that paragraph?

10        A.   Yes, it is.

11        Q.   When did you receive this ID?

12        A.   When I arrived there, five, ten, or 15 days later.  I don't

13     remember when exactly.

14        Q.   It says on this ID "permanent permit."  What does that mean?

15        A.   Well, this was my function, security in the government.  And it

16     was valid as a permanent pass because there were military and police

17     check-points, and this allowed me to move about more easily.  For

18     instance, when I went home or when I escorted a government member.  When

19     I was stopped, I would show them this ID and they would know immediately

20     what I was doing.  If I didn't have that pass, I was supposed to have a

21     military booklet and a pass issued by the military.

22             MR. DEMIRDJIAN:  I apologise for interrupting Mr. Zivanovic.

23     Could we have a more precise answer to your question when you asked:

24             "When did you receive this ID?"

25             The witness does not give us any time-frame.  He just says "five,

Page 11593

 1     ten, 15 days later."  But could we have a month or a year or something

 2     more precise, please.

 3             MR. ZIVANOVIC:  Well, I think that the witness answered the

 4     question, and it did not say about month and years.  He was precise

 5     enough, and he clearly stated that he could not say precisely how many

 6     days after they took this position to provide security to the government

 7     he got this particular document.

 8             JUDGE DELVOIE:  Mr. Demirdjian, you will have discretion for

 9     cross, eventually.

10             MR. DEMIRDJIAN:  Your Honours, I can definitely deal with it in

11     cross.  It's just that at this stage we're left in the dark.

12             MR. ZIVANOVIC: [Interpretation]

13        Q.   One more thing about this pass.  To what extent could you use it

14     as a permit to cross military and police check-points?  Those people who

15     manned those military and police check-points, did they respect this kind

16     of ID?

17        A.   Yes, some did.  Some didn't.

18        Q.   Thank you.  And now can we go to the following paragraph.  And

19     can you also look at the middle image on your screen.  This ID does not

20     depict a date.  Can you try and remember when you were given this ID?

21        A.   I suppose that it was at the beginning of 1992.

22        Q.   You will see in the text -- the letters are a bit small.  Maybe

23     it is not as easily legible as it could be.

24             MR. ZIVANOVIC: [Interpretation] If it could be zoomed in a

25     little.

Page 11594

 1        Q.   It says:

 2             "Authorisation.

 3             "The bearer of this identity card is authorised to check the

 4     identity of citizens and bring them before a responsible organ, to enter

 5     apartments..." And so on and so forth.

 6             Look at the text carefully and then tell us whether you have ever

 7     exercised any of these authorities.

 8        A.   No, I didn't not exercise any of the authorities because I never

 9     had an opportunity to do that, but this was a staple authorisation of the

10     MUP of Serbia and it -- you could find it on every MUP ID.  This is a

11     conventional official ID issued for officials.  It is more serious, as it

12     were, than the previous one; for example, it allowed you to cross the

13     bridge more easily.  But I never had an opportunity to use it, no.

14        Q.   I think you are talking about the ID, that it had more power?

15        A.   Yes, it had more power at check-points.

16        Q.   Yes, I understand.  And can you now look at the authorisation

17     that I've just showed you and read out from.  Do you know if people from

18     the government security exercised those authorities; for example, did

19     they bring people in or entered people's apartments?

20        A.   Nobody from my group did.  I never heard of anybody having done

21     that.

22        Q.   If you were to look at paragraph 21 now.  You said that in 1992

23     you received a new ID from Ilija Kojic but that you quickly returned them

24     and that you do not have a copy of that ID.

25        A.   That's correct.

Page 11595

 1        Q.   During our meeting here in The Hague, you gave me a copy of that

 2     ID card.  When did you find it?

 3             MR. ZIVANOVIC:  May we see, please, 1D3756.

 4             JUDGE DELVOIE:  Mr. Zivanovic, I think we might have a problem.

 5     Your last intervention has not been recorded, neither understood.

 6             MR. ZIVANOVIC:  Oh.  May we have please 1D3756.

 7             JUDGE DELVOIE:  Thank you.

 8             MR. DEMIRDJIAN:  Your Honours.

 9             JUDGE DELVOIE:  Mr. Demirdjian.

10             MR. DEMIRDJIAN:  I don't believe this document is on the

11     Defence's 65 ter list.  I'm not sure if there has been an application on

12     this matter.

13             MR. ZIVANOVIC:  That's correct.  And thank you for... we obtained

14     this and one more document from the witness two or three days ago, and we

15     didn't file, indeed, our motion to amend our Rule 65 ter list.  So I

16     would ask the Chamber to permit amending of this list with these two

17     documents, with 1D3756 and 1D3755.

18             And thank you to my colleague.

19             MR. DEMIRDJIAN:  Your Honours, in relation to this document, we

20     don't have an objection.

21             In relation to the second one, 1D3755, I believe, we are not

22     entirely sure of the relevance of that document.  Perhaps we can deal

23     with it when the subject comes up, but at this stage we do object to its

24     addition to the 65 ter list.

25             JUDGE DELVOIE:  Yes, Mr. Zivanovic.

Page 11596

 1             MR. ZIVANOVIC:  I just can say that 1D3755 just illustrates the

 2     jurisdiction for the issue of the permission for the crossing the bridge,

 3     and it may -- it might be relevant for the Defence case.

 4             JUDGE DELVOIE:  I suppose you will use it with the witness and

 5     tender it; right?

 6             MR. ZIVANOVIC:  Yes, that's correct.

 7             JUDGE DELVOIE:  So then we will decide your 65 ter request.

 8             For the other document, the 3756 one, the 65 ter request is

 9     granted.

10             MR. ZIVANOVIC:  Thank you.

11        Q.   [Interpretation] We have the date when this ID card was issued.

12     Is this the ID card to which you refer in paragraph 21 which you didn't

13     have then when you gave the statement and you have it now?

14        A.   Yes.

15             MR. ZIVANOVIC:  And if we could go back to the previous document.

16     It is 1D3429.

17        Q.   [Interpretation] Let's look at the document at the bottom of the

18     page.  The last copy of that ID.  There is a date here, the 24th of

19     April, 1996.  That's when the ID card was issued, and we can see here

20     that your function was to provide security for the president of the

21     province.  Who was that at the time?

22        A.   Goran Hadzic.  I was his driver and a body-guard.

23        Q.   The date that we see on the screen is the date when you started

24     working as his driver and body-guard; right?

25        A.   Yes, that's correct.

Page 11597

 1             MR. ZIVANOVIC:  Your Honours, I would tender this document and

 2     the document 1D3756 into evidence.

 3             JUDGE DELVOIE:  Admitted and marked.

 4             THE REGISTRAR:  Exhibits D197 and D198.

 5             JUDGE DELVOIE:  Thank you.

 6             MR. ZIVANOVIC: [Interpretation]

 7        Q.   In paragraph 16, which I skipped --

 8             JUDGE DELVOIE:  Mr. Zivanovic.

 9             MR. ZIVANOVIC:  Oh, sorry.

10             JUDGE DELVOIE:  May I remind you that you have 15 minutes left

11     for your examination-in-chief.

12             MR. ZIVANOVIC:  Yes, I'll do it.

13             JUDGE DELVOIE:  Just to let you know.

14             MR. ZIVANOVIC:  Yes, thank you.

15             JUDGE DELVOIE:  In due time.

16             MR. ZIVANOVIC:  Thank you.

17        Q.   [Interpretation] I skipped paragraph 16 in your statement.  In

18     this paragraph, you say that while you provided security for the

19     government in Erdut you also slept there.  Where exactly did you sleep?

20        A.   At the entrance to the manor, there were two rooms.  There were

21     four beds in one of them and three or four in the other.  That was at the

22     very entrance to the manor.  And there was also a reception desk.  That's

23     where we slept.

24        Q.   In paragraph 27, you mentioned Zarko Aleksic.  You say that he

25     spent very little time in the government security.  You said that

Page 11598

 1     Stevo Bogic caught him red-handed and removed him from the security

 2     detail.  What did you mean when you said that he was caught red-handed

 3     while stealing?

 4        A.   There was no fuel at first.  But it was not I who caught him.  It

 5     was Stevo who did it.  Stevo caught him while stealing fuel from a fuel

 6     tank.  And then we had automatic rifles in the room, we had our pistols

 7     also, but we never took any of them out unless needed.  So he stole

 8     ammunition from our only own weapons, from our own rifles and pistols.

 9     So I know that Stevo chased him away; Stevo Bogic.  He caught him

10     red-handed and he didn't want him in the group anymore.

11        Q.   Could you now tell us about paragraph 16 where you mentioned the

12     people who provided security for the government.  You mention him as

13     well.  And you also mention Dragan Lazarevic, Suljo.

14        A.   Yes.

15        Q.   Who was there for only a couple of days?

16        A.   Yes, a couple of days.  Not more than that.

17        Q.   And you said that Susanj -- that Soskocanin and Zarko Aleksic

18     joined you later.  Why did Dusan Soskocanin and Zarko Aleksic join you?

19     Was there something special going on?

20        A.   When Lazarevic, aka Suljo, left, he opened a bar.  San Marino was

21     the name of the bar that he took over from somebody.  Sinisa Gajic, also

22     known as Gaja, was with Aleksic in the same room and then he left.  Ten

23     or 15 days later he decided that he didn't like the situation.  It was a

24     long time ago.  Gajic also left.  And Aleksic was then chased away.  So

25     Dusko Soskocanin, the youngest brother of the other Soskocanin, and

Page 11599

 1     Pero Rakas filled up their places.  Relja Andric also joined us to fill

 2     the vacancies.  Relja was the driver who drove Bogic around, whereas the

 3     rest of us were providing security for the facility.

 4        Q.   Just one more question about the last paragraph, paragraph 31.

 5     You said that you didn't remember the date when you left Croatia.  Did

 6     you in the meantime remember when that was?

 7        A.   Yes.  That was after the -- or at the beginning of the peaceful

 8     reintegration in 1997.  I believe that it was in the month of July.  I'm

 9     not sure.  I believe so.  Either in July or in August.  At the beginning

10     of that or during that peaceful reintegration.

11        Q.   It doesn't matter that much now.  Mr. Dafinic, let me ask you

12     just two more things.

13             First of all, what is written in your statement and what you've

14     said today, is that truthful to the best of your recollection?

15        A.   To the best of my recollection, it is true.

16        Q.   If I were to put to you the same questions today as I did when

17     you were giving the statement, would your answers be the same as then

18     with the corrections you've made today on the record?

19        A.   With those corrections, yes, because some things come back to me

20     as we speak.

21             MR. ZIVANOVIC:  Your Honours, I would tender this document, this

22     statement into evidence.  It is 1D2859.

23             JUDGE DELVOIE:  Again, Mr. Zivanovic, you spoke too hasty.

24             MR. ZIVANOVIC:  Sorry.

25             JUDGE DELVOIE:  I suppose you would tender the statement.

Page 11600

 1             MR. ZIVANOVIC:  Yes, I tender --

 2             JUDGE DELVOIE:  Witness statement.

 3             MR. ZIVANOVIC:  I would tender this witness statement.  It is

 4     1D2859.

 5             JUDGE DELVOIE:  Admitted and marked.

 6             THE REGISTRAR:  Exhibit D199, Your Honours.

 7             JUDGE DELVOIE:  Thank you.

 8             MR. ZIVANOVIC:  [Interpretation]

 9        Q.   Since we have very little time left, I wanted to clear up one

10     more thing.  You said that already on the 2nd of May the Yugoslav

11     Peoples' Army came to Borovo Selo.  Tell me, what was the relationship

12     between the residents of Borovo Selo and the Yugoslav Peoples' Army in

13     this period?

14        A.   It was disappointing.  We had, for instance, moved towards

15     Borovo Naselje about ten times.  When we would advance, the tanks would

16     first support us, then retreat, and people would get killed.  We had lot

17     of people killed, about 80 or 90, 190 were wounded.  This Branko Ciric

18     would inform us where the attack was, then this lieutenant or captain

19     would say, "Go in this direction, advance," and then we would retreat.  I

20     can hardly describe how horrible it was.  We were very angry with the

21     army.  We thought that after all those videos we had seen about the

22     Croats arming and Martin Spegelj, we thought that the army would come

23     very quickly.  They will disarm everybody and things would be resolved

24     quickly, but --

25        Q.   If you could just tell us, again.  You said approximately how

Page 11601

 1     many people were wounded and killed in Borovo Selo.  Could you repeat the

 2     numbers?

 3        A.   Around 250 or 260 wounded and 69 or 79 killed.  There is a book

 4     about that and a memorial to all those killed who were young people

 5     between 20 and 40.  They had families and children.

 6        Q.   Just one more question:  Did you participate in this fighting?

 7        A.   Yes, I did.

 8        Q.   Thank you, Mr. Dafinic.  I have no further questions.

 9             MR. ZIVANOVIC:  Your Honours, I've finished my direct.  Thank

10     you.

11             JUDGE DELVOIE:  Thank you very much, Mr. Zivanovic.

12             Mr. Demirdjian, how about taking the break now and still come

13     back at 11.00, which would give us a little bit more time to look into

14     the scheduling issues and be able to answer those -- your questions right

15     after the break.  I suppose that you will still be able to finish your

16     cross-examination within the two next sessions.

17             MR. DEMIRDJIAN:  I believe so, Your Honours.  Yes.  It shouldn't

18     be a problem.

19             JUDGE DELVOIE:  Thank you.  If that's suitable for everyone,

20     court adjourned.  We come back at 11.00.

21                           [The witness stands down]

22                           --- Recess taken at 10.16 a.m.

23                           --- On resuming at 11.02 a.m.

24             JUDGE DELVOIE:  We looked into the scheduling issues.  The safe

25     conduct motion was briefed only two days ago, and the decision will be


Page 11602

 1     filed before the end of this week.

 2             The videolink Witness 010, the Defence already dealt with it.

 3     Indeed, it will not be feasible to have a videolink established if it

 4     would be -- if the request would be granted.  The decision will also be

 5     filed before the end of this week.

 6             The conclusion is that it seems that we will have an even shorter

 7     hearing week next week than we had this week.

 8             Mr. Zivanovic, unless you could fill in the gaps with viva voce

 9     or 92 ter witnesses that would be ready eventually and for which the

10     Prosecution would be ready as well, and we would certainly encourage you

11     to try to organise that.

12             MR. ZIVANOVIC:  We'll do our best, Your Honour.  That's

13     everything that I could say at this point of time.

14             JUDGE DELVOIE:  All right.

15             The witness may be brought in -- oh, I'm sorry, Mr. Stringer.

16             MR. STRINGER:  Excuse me, Mr. President.  Thank you.

17             Just -- recognising that the issue of witness scheduling is

18     always fluid, and we understand that, but the fact is that the Chamber

19     has been presented with an unprecedented number of videolink motions in

20     this case, possibly an unprecedented number of motions for safe conduct,

21     and, in addition, a number of motions for transfer of witnesses who are

22     in custody.  And, again, recognising that it's fluid, I think that in

23     respect of Witness 10, this is a situation that could have been avoided,

24     and we're -- the Prosecution's going to insist on getting the time, the

25     notice, that it's entitled to under the Rules.


Page 11603

 1             We're concerned, in particular, about the transfer witnesses

 2     being brought on dates with the result being that the Prosecution has

 3     less than the full advance notice that it's entitled.  These are big

 4     witnesses, Mr. President.  The transfer witnesses that we brought, the

 5     dates of their testimony were known to the Defence months in advance.

 6     And we're concerned about the way that this could possibly be managed in

 7     a way that in order to fill the court schedule, it could result in the

 8     Prosecution getting less preparation time for its cross-examinations, and

 9     so I just wanted to mention that because this is something that we do

10     have concern about.

11             JUDGE DELVOIE:  I understand your concern, Mr. Stringer, and

12     that's certainly not the purpose when I asked Mr. Zivanovic to try and

13     organise to fill the gaps.  Your position should indeed be respected and

14     you should have the time you need to prepare for witnesses and with all

15     the consequences that that entails.

16             If nothing else, we can bring in the next witness.  Thank you.

17             Well, it's not the next witness.  It's the witness.

18                           [The witness takes the stand]

19             JUDGE DELVOIE:  Please be seated, Mr. Dafinic.

20             Mr. Demirdjian, for cross.

21             MR. DEMIRDJIAN:  Thank you, Your Honours.

22                           Cross-examination by Mr. Demirdjian:

23        Q.   Good morning.

24        A.   Good morning.

25        Q.   Sir, I have a few topics to deal with on behalf of the

Page 11604

 1     Prosecution.

 2             First of all, can I ask you a few background questions.  During

 3     the war, could you tell us in which part of Borovo you lived exactly?

 4     Sorry, prior to the start of the conflict.  Not during the war.  Prior to

 5     the start of the conflict, which part of Borovo did you live in?

 6        A.   In the centre.  Palih Boraca Street, number 12.  It is the inner

 7     centre.

 8        Q.   Is this close to the city Orthodox church?

 9        A.   Just by the Orthodox church.

10        Q.   Very well.  Another background question, sir.  At the time in

11     1991, were you married and was your wife's name Jovanka Blagojevic?

12        A.   Yes.

13        Q.   Thank you.  Now at paragraph 16 of your statement, you talk about

14     the creation of this security unit which was headed by Stevo Bogic.  Now,

15     can I assume that this was created in September 1991 around the time that

16     the government was created?

17        A.   Yes.

18        Q.   And in this paragraph you mentioned a number of names of members

19     of this unit.  You talked about them this morning, too.  Now, I see that

20     Dragan Lazarevic's nickname was Suljo, and I'm trying to see if any of

21     the others had a nickname.  Could you help us with that?  For example,

22     Sinisa Gajic, was he known as Gaja.

23        A.   Yes.

24        Q.   Okay.  Did David Cesic have a nickname?

25        A.   Ceso.

Page 11605

 1        Q.   Okay.  Here you have Pero -- it's spelled Raks; is that correct?

 2        A.   No, Rakas.

 3        Q.   And what was his nickname, if he had any?

 4        A.   No.

 5        Q.   Okay.  And Zarko Aleksic, did he have a nickname?

 6        A.   The Marine.

 7        Q.   And finally, Dusan Soskocanin, did he have a nickname?

 8        A.   Duci, D-u-c-i.

 9        Q.   Now, according to the statement, Witness, you were born in 1958

10     which means that in 1991 you were around 30 years old, and so was

11     David Cesic; correct?

12        A.   Correct.

13        Q.   How old was Sinisa Gajic at the time?

14        A.   I don't know.  He's two or three years younger than I.

15        Q.   Okay.  And is it correct that Zarko Aleksic was pretty young,

16     much younger than you, perhaps around 20 years old?

17        A.   Yes.  All these people whom you enumerated formed a circle of

18     friends in the village, and this Zarko Aleksic was much younger that I,

19     12, 13 years, maybe more.  I didn't even know him until then.

20        Q.   Now this circle of friends that you mentioned, did that include

21     also Pero Rakas?

22        A.   Yes, yes.

23        Q.   Okay.  And was Rakas also around your age?

24        A.   Yes.  He was born in 1958, I think.

25        Q.   Very well.  Now are you still in contact with the -- this circle

Page 11606

 1     of friends that you mentioned who are around your age?

 2        A.   Well, I am in contact with Cesic because he lives not far from

 3     me.  Sinisa Gajic was killed in an involuntary homicide.  I don't see

 4     Suljo anymore; he lives in Novi Sad.  With Relja Andric, I see him

 5     sometimes.  He comes to my family celebrations, I go to his, et cetera.

 6        Q.   And you just said a moment ago Mr. Cesic lives not far from you.

 7     Which town do you live in currently?

 8        A.   Now I live in Novi Sad.  The neighbourhood is called Sajlovo --

 9             THE INTERPRETER:  The interpreter didn't hear the name of the

10     street.

11             THE WITNESS: [Interpretation] 17th Street, number 7.

12             MR. DEMIRDJIAN:

13        Q.   Very well.  Now, in your statement, and that's at paragraph 27,

14     you mention that Zarko Aleksic spent little time in the government

15     security.  And could you tell us what does that mean, "little time"?  Do

16     you have a time-frame in mind?

17        A.   Well, after all this time, I can't remember exactly but it was

18     10, 15 days, maybe a month.  It was a very long time ago, and it wasn't

19     important to me.

20        Q.   Now this morning you also said that Sinisa Gajic left and that

21     Suljo also left.

22        A.   Yes, yes.

23        Q.   Now, sir, these are details that we found out for the first time

24     this morning and these are not incorporated in your statement.  Is there

25     any reason why?

Page 11607

 1        A.   There is no reason.  They were not happy with the job.  They were

 2     bored.  They just did not want to do that.

 3             JUDGE DELVOIE:  Mr. Zivanovic.

 4             MR. ZIVANOVIC:  Sorry.  In the witness statement in paragraph 16,

 5     it is explicitly said that Dragan Lazarevic, Suljo, left after a few

 6     days.

 7             MR. DEMIRDJIAN:  The copy that I have says he came a few days

 8     later.

 9             MR. ZIVANOVIC:  No.  I can't see the English translation.

10             MR. DEMIRDJIAN:  In this paragraph --

11             MR. ZIVANOVIC:  It's not correct.  It's not correct.  It is an

12     error in translation.  In the original or B/C/S text, it says he left

13     after "onja" [phoen] -- I'll read it in B/C/S.

14             "With Dragan Lazarevic, aka Suljo, who left after a couple of

15     days..."

16             MR. DEMIRDJIAN:  Well, I've been misled by the translation, then.

17        Q.   Now, sir, I'd like to move on to Mr. Goran Hadzic.  Since when do

18     you know him?

19        A.   I met Zoran [as interpreted] Hadzic after he was released at

20     Plitvice.  I met him in Vukasin Soskocanin's house.

21        Q.   And that's the first time you met him?

22        A.   I don't understand.

23        Q.   Was that the very first time that you encountered Mr. Hadzic?

24        A.   Yes.  That was the first time.

25             MR. DEMIRDJIAN:  Your Honours, just on the basis of this error of

Page 11608

 1     translation that we have in the statement, I would ask that this

 2     statement be revised and MFI'd pending a revision to ensure that we have

 3     an accurate English translation, because this is quite an important

 4     error.

 5             JUDGE DELVOIE:  We will MFI the document, Mr. Demirdjian.

 6             MR. DEMIRDJIAN:  Thank you.

 7        Q.   Sir, I just want to clarify something in your answer.  You said:

 8             "I met Zoran Hadzic after he was released at Plitvice."

 9             I just want to make sure that you meant Goran and not Zoran.

10        A.   I meant Goran Hadzic because I don't know any Zoran Hadzic.

11        Q.   Thank you very much.  Now, in your statement you talk about

12     Mr. Hadzic's arrest in Plitvice with Borivoje Savic.  Now, is it correct

13     to say that when this happened the Serb population in Borovo Selo was

14     outraged by this; is that right?

15        A.   Could you please repeat that question?

16        Q.   The question is that when Mr. Hadzic was arrested at Plitvice,

17     the population, the Serb population, in Borovo Selo was outraged by this.

18        A.   Correct.

19        Q.   And let me ask you, were they outraged not just because it was

20     just anyone but because it was one of their leaders who was arrested; is

21     that right?

22        A.   That's not right.  Boro Savic was also arrested.

23        Q.   Yes.  And what I meant by my question is:  By their arrest, by

24     Hadzic and Savic being arrested, what was -- what was upsetting to the

25     population in Borovo Selo was that there was two of their leaders who are

Page 11609

 1     arrested.

 2        A.   Yes, that's correct.

 3        Q.   Now, after Mr. Hadzic was released, how frequently did you see

 4     him?

 5        A.   I first saw him that time in Vukasin's house, and then I didn't

 6     see him again until the government of the Srem and Baranja district was

 7     formed.

 8        Q.   And from that point on, would it be correct to say that you had

 9     almost daily interactions with him?

10        A.   I don't understand.

11             MR. ZIVANOVIC:  May I -- sorry for interrupting, but I think that

12     the question was asked and answered.

13             MR. DEMIRDJIAN:  So maybe I'll clarify.

14        Q.   I mean to say from the moment that you joined the security unit

15     headed by Mr. Bogic, from that moment on, would it be fair to say that

16     you saw Mr. Hadzic almost on a daily basis?

17        A.   No, not on a daily basis but occasionally.  From time to time.

18        Q.   All right.  So from time to time you -- you told us this morning

19     you were sleeping in the entrance in the rooms at the Dvorac, at the

20     castle; right?

21        A.   Yes.  Correct.

22        Q.   And that is where Mr. Hadzic had his seat or his headquarters;

23     correct?

24        A.   Correct.

25        Q.   So from a daily basis, perhaps that's not the frequency with

Page 11610

 1     which you saw him, would you see him on a weekly basis?

 2        A.   Well, whenever I stood at the gate and he entered, I saw him.

 3     Sometimes I was not there myself.  I didn't stand at the gate 24 hours a

 4     day.  There were other people who took turns with me.  So sometimes he

 5     went in when I was not guarding the gate.

 6        Q.   Now, so you stated this morning that after Mr. Hadzic and Savic

 7     were arrested at Plitvice, barricades were erected in Borovo Selo and

 8     talks were held to remove these barricades.  Now, are you able to tell us

 9     when was Mr. Hadzic and Mr. Savic, when were they arrested?  Do you

10     remember the date?

11        A.   No, I don't remember.

12        Q.   Are you able to tell us when the barricades were raised in

13     Borovo Selo?

14        A.   Well, after they were arrested.

15        Q.   Was it the same day, the very next day, a few days later?

16        A.   I don't remember exactly.

17        Q.   And after the moment that they were raised, how much time elapsed

18     until they were removed?

19        A.   They would be removed when an agreement was made with

20     Vukasin Soskocanin.  Then they would be set up again, then they would be

21     removed and set up again, and so on.  Several times.

22        Q.   But you're not very clear about the time-frame.

23        A.   No, no.

24        Q.   Okay.  I will move on to a different topic, Mr. Dafinic.  Are you

25     familiar with the following name, Mr. Radenko Dragovic who's alleged to

Page 11611

 1     have been a commander for the logistics in the Borovo Selo

 2     Territorial Defence?

 3        A.   Yes, I know that.  I think he was even deputy commander of the

 4     TO, the Territorial Defence.

 5        Q.   And is he still alive?

 6        A.   Dragovic, yes, he is.

 7        Q.   Have you seen him recently?

 8        A.   Well, he's sickly and ill.  I haven't seen him in a long time.

 9     He is retired.  He suffers from diabetes.  He doesn't move around much.

10        Q.   How about Mr. Radenko Alavanja?  Have you seen him recently?

11        A.   I have not seen him in more than three years.  Three years ago we

12     discussed some potential business opportunity to grow chinchillas.  He

13     was already doing it, and I wanted to join him but then I gave up.  That

14     was three years ago and, since then, I haven't seen him.

15        Q.   And Mr. Cesic you said you're still in touch with him.  So you

16     still see him regularly?

17        A.   He is a neighbour of mine.

18        Q.   Very well.  Sir, I'd like to go back to 1991 when you joined the

19     Serbian national security.  Is it correct to say that up to that point,

20     you had never worked to protect anyone's physical security; is that

21     correct?

22        A.   No, no, no.

23        Q.   I'd like to ask you:  What was the selection criteria applied by

24     Mr. Bogic to recruit members of the Serbian national security?  Is it

25     mainly people that he was familiar with?

Page 11612

 1             MR. ZIVANOVIC:  Sorry.

 2             JUDGE DELVOIE:  Mr. Zivanovic.

 3             MR. ZIVANOVIC:  It requires for speculation, what criteria had

 4     Bogic in the choice of security.

 5             MR. DEMIRDJIAN:  This is not speculation.  I'm asking him about

 6     his knowledge, not the witness's knowledge.

 7             JUDGE DELVOIE:  Please proceed, Mr. Demirdjian.

 8             MR. DEMIRDJIAN:  Thank you, Your Honours.

 9        Q.   Would you lying me to repeat the question, Mr. Dafinic?

10        A.   No.  It was on a friendly basis.  We all knew each other.  He had

11     to ask somebody.  He couldn't ask somebody he didn't know.  We are

12     talking about a small village with 8.000 inhabitants.  We knew each

13     other, but there was a circle of friends who knew each other from bars

14     and disco clubs.  I knew him because he went to school with my wife.  And

15     he knew Pero Rakas because we are more or less of the same age.  He was

16     two, three years younger than me.  So he knew me, he knew others, and he

17     asked the people whom he knew.  Maybe he asked others as well, but I'm

18     aware of only these people.

19        Q.   Now, by providing security to the government, did that involve

20     escorting government ministers to certain places wherever they were

21     going?

22        A.   Yes, some.  Some were on the escort detail, some stayed back.

23        Q.   And did that change or did you always have the same assignment?

24        A.   Are we talking about providing escort for the government?

25        Q.   Yes.  You said that some people provided -- some were on the

Page 11613

 1     escort, some stayed back.  Would one person always do the same thing or

 2     would they change?  Would they sometimes provide escort and sometimes

 3     provide security to the building?

 4        A.   Yes, we took turns.  Although Relja Andric always drove

 5     Stevo Bogic around.

 6        Q.   Okay.  Now with respect to escorting ministers, did you also

 7     provide escort to Mr. Goran Hadzic?

 8        A.   No, no.

 9        Q.   And --

10        A.   We never drove in a column.  He would leave either before the

11     rest of the people or after them.  We escorted Stevo Bogic with Susa.  It

12     depended on the room in the car.  One or two of us went, whereas the rest

13     stayed and secured the facility.  We couldn't all leave that position.

14        Q.   Very well.  Now with respect to Mr. Hadzic's movements, who would

15     escort him?

16        A.   Milenko Japundzic was the one who escorted him.  As well as

17     Ljubo, Ljubo, Ljubo ... the late Ljubo Mudrinic.

18        Q.   Now amongst your colleagues in your Serbian National Security

19     Service, would you sometimes share amongst yourselves your experience in

20     escorting government members?

21             MR. ZIVANOVIC:  Sorry, the witness -- there is no foundation for

22     this question.  The witness never mentioned that he was -- he has any

23     colleagues Serbian national security.  He didn't mention such

24     organisation.

25             MR. DEMIRDJIAN:

Page 11614

 1        Q.   I'm talking about your unit, Mr. Dafinic, the one headed by

 2     Mr. Bogic.  Just to be perfectly clear.  Within this unit, did it ever

 3     occur that you shared some information with them about problems you faced

 4     in your day-to-day assignments?

 5        A.   First of all, we were no Serb national security at all.  That's

 6     number one.

 7             Second of all, we were not a unit, and we had never discussed

 8     problems.  We only asked each other whether everything was all right,

 9     whether anybody entered with weapons.  Borivoje [as interpreted] would

10     tell us where to go, and Borivoje would inquire as to what had happened

11     during the day.  And he would inquire that of the person who was on

12     sentry duty at that moment.  We were not a unit at all.

13        Q.   Sorry, you mentioned the name Borivoje here.  Who you are talking

14     about?

15             MR. ZIVANOVIC:  As far as I see, this name was -- found its way

16     to the transcript.  The witness did not mention any such name.

17             MR. DEMIRDJIAN:  Any name --

18             MR. ZIVANOVIC:  Borivoje.

19             MR. DEMIRDJIAN:

20        Q.   Sir, did you mention any name at all?  Who would tell us where to

21     go.  You said "somebody would tell us where to go."

22        A.   Stevo Bogic.

23        Q.   Thank you.

24        A.   No Borivoje.  I did not mention any Borivoje.  No.

25             MR. DEMIRDJIAN:  That's probably an error in the transcript.

Page 11615

 1        Q.   Now, sir, coming back to my question, this is exactly what I was

 2     asking you about.  You did share some information about how your day

 3     went, and the reason why I'm asking you this is again because none of the

 4     members of your unit had any training in securing government members.  So

 5     is it correct to say that you did share some information to keep each

 6     other abreast of problematic situations, et cetera?

 7             JUDGE DELVOIE:  Mr. Zivanovic.

 8             MR. ZIVANOVIC:  May we know -- maybe this question should be more

 9     clear about problematic situation.  I don't know what the Prosecution

10     refers to.

11             MR. DEMIRDJIAN:  We will come to that in a moment.  I'm just

12     inquiring at this stage whether the witness shared information with his

13     colleagues about their day-to-day work.

14             JUDGE DELVOIE:  Please proceed, Mr. Demirdjian.

15             MR. DEMIRDJIAN:

16        Q.   Yes, Mr. Dafinic.  You may answer the question now.

17        A.   Please repeat the question.

18        Q.   So the question was, and this is to confirm what you just told us

19     earlier, you would share or talk to your colleagues about what happened

20     that day.  You shared information about situations you faced.

21        A.   Correct.

22        Q.   As part of your work, did there ever come a time where either

23     through your work or through your colleagues' work you faced a situation

24     when a government member was being followed?

25        A.   Yes.

Page 11616

 1        Q.   And who was that government member?

 2        A.   I don't remember.  When there was an assembly meeting in

 3     Beli Manastir, we went there.  When there was a meeting in Borovo Selo,

 4     we went there.  Some of us, though.  When there was a meeting in Knin, we

 5     went there.  The government members went and each of them had a driver.

 6     So we escorted the entire government.  Two or three of us would go to be

 7     of help.

 8        Q.   Let me clarify my question.  My question was:  As part of your

 9     work where you escorted the government, did you ever receive information

10     that one of the government members was being followed or stalked?  That

11     somebody was following him.

12        A.   No, no, no.

13        Q.   Sir, did you know a minister by the name of Slavko Dokmanovic?

14        A.   Yes.

15        Q.   Did you ever have to provide him security or escort?

16        A.   Never.

17        Q.   And how would you describe your relationship with Mr. Dokmanovic?

18     How familiar were you with him?

19        A.   We were not close.  We were on the basis of just greeting each

20     other.  He would inquire how we were and that was that.

21        Q.   Sir, earlier this morning my learned friend showed you some of

22     the identification cards that you had provided him copies of.

23             MR. DEMIRDJIAN:  And I would like us to pull them up at this

24     moment.  I believe that they were admitted as D197.  Yes.  I'd like us to

25     start with the very top one.  If we can zoom on that one, please.

Page 11617

 1        Q.   Now, this morning you told us that you received this first card

 2     about 5, 10, or 15 days after you joined the government security led by

 3     Mr. Bogic.

 4             First of all, this one includes your name and your post, and it

 5     is signed by the president of the government, Mr. Goran Hadzic; is that

 6     correct?

 7        A.   Correct.

 8        Q.   And this card is the one that you had until when, until 1992,

 9     until the RSK was formed; is that right?

10        A.   When was the RSK formed?  After the assembly meeting -- or when?

11     I don't understand.

12        Q.   Sir, the question is:  This first card, this first ID card that

13     is in front of us, this is the card that you had with you and used -- or,

14     well, you had in your possession until the government of RSK was created

15     in 1992 at which time you were issued this second card.  Do I understand

16     that correctly?

17        A.   Yes, the second.  Yes, yes, yes.  Yes.

18        Q.   Thank you very much.  Now, the second card here.  First of all,

19     we see your picture and everything, but does this also have a cover page?

20     Is there a cover to this ID or is it just a one-sided ID card?

21        A.   There was a cover page which depicted the words "official ID

22     card."  It was blue and all you could see on the cover page was the words

23     that I just gave you.

24        Q.   Do you have that ID card with you right now?

25        A.   Yes, I do have it.  Not on me at the moment.

Page 11618

 1        Q.   Could I ask you to bring it with you at the next break?  Do you

 2     have it in the building here?

 3        A.   In the building?  Here?  Yes.

 4        Q.   Thank you.  If you could bring it after the next break.  I would

 5     like to be able to see it.  Now, did this --

 6        A.   I believe do that.

 7        Q.   Sorry, thank you.  This one has a bit more details than the first

 8     card.  Now, is this picture a picture of you in -- taken in 1991?

 9        A.   Yes, yes.

10        Q.   Very well.  And under this we see your name, function, and your

11     signature.  And then the signature of the president of the government.

12     On the right side, we see the details which give you the power to check

13     the identity of citizens and bring them before responsible organs,

14     et cetera.

15             This morning when you were shown these cards, you told us that --

16     let me see what was the wording you used.  You said that these were

17     staple authorisations of the MUP of Serbia.  Do you remember saying that

18     this morning?

19        A.   That's correct.

20        Q.   And these -- looking at the watermark here and looking at the ID,

21     the second one, and -- with the picture, was this a MUP ID or was this an

22     ID of the Republic of Serbian Krajina?

23        A.   The Serbian District of Slavonia, Baranja, and Western Srem, and

24     the third one of the Serbian MUP featuring the same authorities.  You

25     didn't want to show it.  I received it in 1992.


Page 11619

 1        Q.   What I'm trying to get at, sir, is this second ID we see with

 2     your picture and the two stamps, was this an ID of the MUP of Serbia or

 3     was this an ID of the MUP of the Republic of Serbian Krajina?

 4        A.   It says --

 5             JUDGE DELVOIE:  Mr. Zivanovic.

 6             THE WITNESS: [Interpretation] -- the Republic of Serbian Krajina,

 7     the Serbian District of Slavonia, Baranja, and Western Srem.  That's what

 8     I'm reading.

 9             MR. DEMIRDJIAN:

10        Q.   Very well.  Thank you for that clarification.  Now, sir, bearing

11     in mind the authorisation that we see on the right side, I would like to

12     show you another document.

13             MR. DEMIRDJIAN:  This would be 65 ter 6534 at tab 14 in the

14     Prosecution's list.

15             And actually, Your Honours, for the use of this document, we

16     would need to go in private session.

17             JUDGE DELVOIE:  Private session, please.

18                           [Private session]

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 11620











11 Pages 11620-11623 redacted. Private session.
















Page 11624

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22                           [Open session]

23             THE REGISTRAR:  We're in open session, Your Honours.

24             JUDGE DELVOIE:  Thank you.

25             MR. DEMIRDJIAN:  In fact, if it pleases the Court, I could inform


Page 11625

 1     the Chamber or the Registry during the break which -- from which portion

 2     we should have left to remove the private session marking.

 3             JUDGE DELVOIE:  It would be helpful.

 4             MR. DEMIRDJIAN:  Thank you.

 5        Q.   Sir, we have a document here in front of us dated February of

 6     1992.  Yes.  It's a document signed by Mr. Bogic, and you can see in the

 7     header, it says:  "Serbian District of Slavonia, Baranja, and Western

 8     Srem."  In the top left-hand corner, the words "Serbian National

 9     Security."

10             Now, sir, did you ever hear the name being used at the time?

11        A.   That's a question better put to Stevo Bogic.  He mentioned that

12     some sort of unit was to be established, but as far as I know it never

13     materialised.  I think this is not a question for me.  It's a question

14     for him.

15             As for myself, I know that I was never part of any Serbian

16     national security because it had never been set up.  He was just talking

17     about it, saying that it would be established one of those days but as

18     far as I know it never happened.  I did not have any insight into these

19     documents.  I was a guard standing at the door.  I was part of a security

20     detail.  This question is really for someone else to answer.

21        Q.   Thank you, sir.  So in your day-to-day interactions with

22     Mr. Bogic -- in fact, you were not familiar with what Mr. Bogic was doing

23     with respect to documentations and requests of this kind; is that right?

24        A.   When he was deputy prime minister and I was a guard standing at

25     the door, why would he tell me these things?  Of course I didn't know and

Page 11626

 1     he didn't see me every day.  Sometimes we wouldn't see each other for two

 2     or three days.  The person at the reception standing at the door would

 3     tell him, "What's new?  Do you have any problems?  Were you well fed,"

 4     et cetera.  "Hello," "goodbye."  That was it.

 5        Q.   Very well.  Now, sir, in your statement at paragraph 26, you say

 6     that your unit -- well, what did you say exactly?  "We."  "We never

 7     arrested people or take them into custody or investigate them."

 8             Is that your evidence?

 9        A.   You're talking about a unit again.  I said "group."  We were no

10     unit.  We were a group of guards.  Everybody knows what a unit means.  A

11     unit of five or six men is no unit in my understanding.  And you can call

12     it as you please.

13        Q.   Let's settle for "group" and we'll settle this question once and

14     for all.  Now, this group of yours, you say, never arrested people or

15     take them in custody.  Is that your evidence?

16        A.   That's right.

17        Q.   And just to be perfectly clear, what you're telling us is that it

18     never happened that members of your group went to someone's house and

19     brought them over for detention or interrogation?

20        A.   Yes, that's correct.  As far as I know.  Because we didn't even

21     have a prison.  We had two dormitories.

22        Q.   I will return to this issue in a moment.  However, were you

23     familiar with the fact that prisoners were detained at Arkan's training

24     centre, just across from your building?

25        A.   No, no.  I did not know because I had no access there.  I could

Page 11627

 1     not get such information.

 2        Q.   You didn't hear any suggestions that prisoners were detained in

 3     the training centre?

 4        A.   There was all kind of talk, but I would not have been able to

 5     hear that kind of talk.  I could have only found out later.  While I was

 6     there, I couldn't know anything about it because I repeat literally

 7     nothing.  Later on when it was all in the past, I heard some stories of

 8     the kind you mention now.

 9        Q.   Sir, at the time you didn't hear yourself any sounds of beatings?

10        A.   How could I hear myself when I was 1 kilometre away?  Okay, not 1

11     kilometre but 500 metres.  I was either at the entrance or in the

12     dormitory.  I did not hear any screams any moments [as interpreted].  I

13     heard only their singing.  While they were running, exercising, they were

14     singing.  That's the only thing you could hear.

15        Q.   Sir, 500 metres is quite a long distance.  Are you saying that

16     the distance between the government building and the training centre was

17     500 metres?

18        A.   Sure, certainly.  If it was not 500, it was 450.

19        Q.   Sir, this morning you made a correction to your statement and you

20     amended what you had in your statement to be 250 metres to 500 metres;

21     right?  In respect to distance in Borovo.

22        A.   Well, I confused it with the football pitch.  I said at the

23     beginning 500 reckoning with the distance between the football pitch and

24     the tavern, and I -- and I reckoned that it could be those streets of 20

25     metres each plus the football pitch.  That's why I said 250.  My house

Page 11628

 1     overlooked the pitch.  There was the church, then my house, and the pitch

 2     that my house was facing.  But if the pitch is not 500 metres, then it

 3     could be less.

 4        Q.   Sir, I would like you to take a look at a document quickly before

 5     the break.

 6             MR. DEMIRDJIAN:  It is Exhibit P130 at tab 20.  Yes.

 7        Q.   Sir, this is a document you probably have not seen before.  It is

 8     information --

 9        A.   Could you make it a bit larger?

10        Q.   Yes.  On the top left-hand corner, you see Command of the

11     1st Military District, and it is dated October of 1991.  And the title

12     is:  "The conduct of the Commander of the Special Forces of Slavonia,

13     Baranja, and Western Srem ... 'Arkan' in Erdut."  This is a military

14     report.

15             MR. DEMIRDJIAN:  I would like us to go to page 3 in the English

16     version and page 2 in the B/C/S version.  And we can zoom on the bottom

17     part of the B/C/S version.  Yes.

18             THE WITNESS: [Interpretation] You are flipping through the pages

19     too quickly.  I didn't manage to read it.

20             MR. DEMIRDJIAN:

21        Q.   Very well.  I want you to focus on this part of the report

22     because the other parts of the report are of no concern to us at this

23     moment.

24             It talks about Arkan and his activities.  And it says:

25             "In the centre" --

Page 11629

 1             And I'd like to remind you this document is drafted from October

 2     of 1991.

 3             "... Arkan is engaged in the slaughter of the prisoners sent by

 4     the local territorial units.  He observed a man being beaten with a

 5     baseball bat, after which they put him on the nylon to bleed to death.

 6             "He observed them putting rifles with silencers against the back

 7     of the head of four men and killing them in that way.  Following the

 8     slaughter of these four men, who were then thrown in the Dunav River, he

 9     personally wiped off the blood."

10             Sir, were there any rumours at that time about prisoners being

11     thrown in the Danube river?

12        A.   Not that I know.  I am not aware of this.  Maybe the person who

13     did this was aware of it, and I don't suppose they would talk about it.

14     This is the first time I hear of it.  I don't know.  I really don't know.

15        Q.   Sir, your building was in the same compound as Arkan's training

16     centre.  Here we have a military report from the 1st Military District

17     whose headquarters are quite removed from Erdut, and you're telling us

18     that you have never heard of this?

19             MR. ZIVANOVIC:  Sorry.

20             JUDGE DELVOIE:  Yes, Mr. Zivanovic.

21             MR. ZIVANOVIC:  I don't know that these two objects were in the

22     same compound, and I don't see any foundation for such a question.

23             MR. DEMIRDJIAN:  Your Honours, I could refrain or rephrase the

24     question, I see it's the break, though.

25             So before we go on break, however, Your Honours, I did fail to

Page 11630

 1     tender the document I showed earlier with respect to Mr. Ulemek.  This

 2     was 65 ter 6534, tab 14.  We wish to tender this document.

 3             JUDGE DELVOIE:  Yes, Mr. Zivanovic.

 4             MR. ZIVANOVIC:  I would object because the witness didn't know

 5     anything about this document and it is not -- there is no foundation for

 6     tendering this document through this witness.

 7             MR. DEMIRDJIAN:  Mr. President, Your Honours, the witness is

 8     familiar with the individual who is referred to in the document.  He is

 9     familiar with the ID card that he personally possessed.  We are

10     submitting it to ascertain the fact that there is a match between these

11     IDs and that this person did, in fact, have an ID card as described in

12     the document.

13             MR. ZIVANOVIC:  First of all, the purpose of this document is

14     not, as far as I know, whether the witness know Mr. Ulemek or not, but

15     the match between these IDs.  We did not see Ulemek's ID, and we don't

16     know about authenticity and credibility of this card mentioned in this

17     report.  Because of that, I think that there is no foundation to tender

18     this document through this particular witness.

19             JUDGE DELVOIE:  The objection is overruled.

20                           [Trial Chamber confers]

21             JUDGE DELVOIE:  Mr. Witness, you wanted to intervene?  Yes?

22             THE WITNESS: [Interpretation] I did want to intervene.  As far as

23     I was able to read from that official ID card, I had not seen that ID

24     card as I did mine, but it is -- it has the same writing, the same text

25     as my ID card, but I didn't see it.  I didn't see his actual ID with his

Page 11631

 1     photo on it.  He could have written it himself.  I saw that kind of ID

 2     several times, and now I find out that he had the same kind, Ulemek.  He

 3     didn't have our ID card.  He had the ID card of Arkan's unit.

 4             JUDGE DELVOIE:  The objection is overruled.  The document is

 5     admitted and marked.

 6             THE REGISTRAR:  Does 65 ter number 6534 need to be under seal?

 7             MR. DEMIRDJIAN:  It is meant to be under seal.  Thank you for

 8     reminder.

 9             THE REGISTRAR:  Exhibit P3263, under seal, Your Honours.

10             JUDGE DELVOIE:  Thank you.

11             MR. DEMIRDJIAN:  And, Your Honours, I believe it is the

12     appropriate time.

13             JUDGE DELVOIE:  Yes, indeed.  There is one little detail I wanted

14     to mention.

15             On the document we MFI'd which was the witness statement of this

16     witness, right, Mr. Demirdjian?

17             MR. DEMIRDJIAN:  Yes.

18             JUDGE DELVOIE:  I suppose then there were another -- I suppose

19     it's a confusion, but another issue will be resolved; namely, that the

20     witness statement says that the witness has been interviewed by

21     Mr. Zoran Zivanovic and by -- and then there is the witness's name.  I

22     don't suppose he is interviewed by himself.  Just -- I want to have that

23     on the record.

24             Mr. Witness, we take the second break.  We'll come back at 12.45.

25             Court adjourned.

Page 11632

 1                           --- Recess taken at 12.16 p.m.

 2                           [The witness stands down]

 3                           --- On resuming at 12.46 p.m.

 4             JUDGE DELVOIE:  I think this morning I forgot to mention for the

 5     record, so do I it now, that today we sit pursuant to Rule 15 bis;

 6     Judge Mindua being absent.

 7                           [The witness takes the stand]

 8             JUDGE DELVOIE:  Mr. Demirdjian, please proceed.

 9             MR. DEMIRDJIAN:  Thank you, Your Honours.

10             And, Your Honours, as promised before the break, I did look back

11     at the transcript at the portion which was in private session.  I believe

12     that as of page 46, line 2, we can assume that this is back in private

13     session [sic] as nothing was said about the document any further from

14     that point on.

15             JUDGE DELVOIE:  Just one moment.

16             MR. DEMIRDJIAN:  So I called the document at page 42, line 18.

17             JUDGE DELVOIE:  Yes.

18             MR. DEMIRDJIAN:  So from that -- yes.

19             JUDGE DELVOIE:  You say:  "As of page 46, line 2, we can assume

20     that this is back in private ..."

21             MR. DEMIRDJIAN:  In open.

22             JUDGE DELVOIE:  Open.

23             MR. DEMIRDJIAN:  Sorry.

24             JUDGE DELVOIE:  That's totally different.  The private -- we lift

25     the qualification private session as from that point.

Page 11633

 1             Please proceed, Mr. Demirdjian.

 2             MR. DEMIRDJIAN:  Thank you, Your Honours.

 3        Q.   Mr. Dafinic, I would like to ask you about the statement that you

 4     gave to the Defence.  Could you tell us first what was the very first

 5     time that you got in contact or communicated with Mr. Hadzic or any

 6     members of his Defence team about testifying in this case?

 7        A.   I did not have contact with Mr. Hadzic.  I had contact on the

 8     29th of May, 2014 with Mr. Zivanovic.

 9        Q.   I'm asking you about the very first time, not the very last time.

10     So the 29th of May you signed this statement.  But what was the first

11     time that you communicated with the Defence team of Mr. Hadzic?

12        A.   Yes, well, it was in April.  Perhaps one month before.

13        Q.   So that was the very, very first time?

14        A.   In the month of April, the first time and the last time.

15        Q.   Well, the first time time was in April.  Is that what you're

16     saying?

17        A.   Yes, yes.

18        Q.   Now, could you tell us where -- were you met in Novi Sad where

19     you live?

20        A.   Yes, in Novi Sad.

21        Q.   And both in April and in May you met the Defence team in

22     Novi Sad?

23        A.   I met with Zoran in April; and in May; I met with Aleksandar from

24     his team to sign the statement.

25        Q.   Okay.  I would like to take you first to the meeting in April.

Page 11634

 1     Where exactly in Novi Sad did this take place?

 2        A.   In the centre of Novi Sad.  In the offices of Mico Crnogorac.

 3        Q.   This is a lawyer, I assume.

 4        A.   No, it's not law firm.  It's a friend's office.

 5        Q.   Well, you said that Mr. Zivanovic was present during the

 6     interview.  Was anyone else present while -- during this interview?

 7        A.   Yes, there was.

 8        Q.   Okay.  And tell us who else was there?

 9        A.   He and I conducted the interview together, and David Cesic, I

10     think, was present.  I don't know.  As soon as I finished the interview

11     with him, I left.

12        Q.   How long did the interview last?

13        A.   An hour and a half, I think.

14        Q.   Okay.  And when you met again in May to sign the statement, was

15     it in the same office?

16        A.   Yes.

17        Q.   And was Mr. David Cesic present as well when you signed the

18     statement?

19        A.   Yes.  I got the statement to read and to sign.

20        Q.   And both in April and May when you met in this office, was

21     Mr. Cesic part of the discussions during the interview?

22        A.   No.

23        Q.   Was he present in the office?

24        A.   In another office.

25        Q.   Now this morning we saw the ID card which had gone missing.  You

Page 11635

 1     mention this at paragraph 21.  And I would like to take you to paragraph

 2     21 of your signed statement.  Do you have it in front of you?  You see

 3     here at paragraph 21 you say that:

 4             "After the formation of the RSK, we received new identity cards

 5     from Ilija Kojic, but for some reason, I do not know why, we had to

 6     return them after a month, which is why I do not have this identity

 7     card."

 8             So I'm curious to know, how did you find it?

 9        A.   Well, I photocopied all the documents I received.  From day one,

10     I made photocopies in order not to lose them and also to keep them as a

11     memento.  In case they had to returned or were taken away, I wanted to

12     have photocopies.  So I found, quite by chance, this photocopy among my

13     documents in Novi Sad.

14        Q.   Very well.  I would like to move to another topic.  You mentioned

15     Vukasin Soskocanin at paragraph 3 of your statement, and you mention that

16     he organised the guards in Borovo Selo after Hadzic's arrest and Savic's

17     arrest in Plitvice.  Now, at this paragraph here you add that:

18             "At this time Vukasin Soskocanin was not a member of the SDS but

19     he joined later."

20             Right?  The last sentence of paragraph 3, this is what you say.

21     He was not a member of the SDS.  He joined later.

22             Now, sir, we know that Mr. Hadzic and Mr. Savic were arrested on

23     the 31st of March, 1991, and we know that Vukasin Soskocanin was killed

24     on the 15th of May, 1991, so six weeks later.  So how and when during

25     this six-weeks period did he join the SDS, if you know?

Page 11636

 1        A.   Well, I think he joined the SDS even later than that.  Not within

 2     those six weeks.  Later than that.  I don't know the exact date.  He was

 3     imagining a different kind of movement.

 4             MR. DEMIRDJIAN:  Can we pull up the Exhibit P65.50, Your Honours.

 5     It's at tab 2.

 6        Q.   And while this is coming up, Mr. Dafinic, I'm not sure I quite

 7     understand your answer.  I'm telling you that six weeks after

 8     Mr. Hadzic's arrest, Vukasin Soskocanin was killed on the 15th of May,

 9     and you're saying he was -- he joined the SDS even later than that?  I'm

10     not sure I understand exactly your answer.

11        A.   Here it is.  When Goran Hadzic and Boro Savic were released at

12     Plitvice Lakes, they came to see Soskocanin.  They came for a meeting

13     which I also attended, although I didn't come in to listen to what

14     they're talking about.  But he was not a member of the SDS then.  As far

15     as I know, he joined later.  Maybe he had joined earlier, but not that I

16     know.  To the best of my knowledge he joined the SDS, became a member,

17     later.  Maybe he had joined earlier without telling me, but the fact that

18     he was meeting with Goran Hadzic and Savic does not necessarily mean he

19     was a member of the SDS.

20             MR. DEMIRDJIAN:  It's Exhibit P62.50.  I see that it was recorded

21     as P675.

22             THE WITNESS: [Interpretation] Stevo Bogic got him to sign up to

23     the SDS.  Stevo Bogic could know the date, when Soskocanin joined the

24     SDS.

25             MR. DEMIRDJIAN:  I apologise.  I apologise.  It's P65.50.

Page 11637

 1        Q.   Just a second, Mr. Dafinic.  The document will come up in a

 2     moment.  This is not the right one.

 3             MR. DEMIRDJIAN:  Thank you.

 4        Q.   Do you see the document on your screen?  It is dated the 12th of

 5     November, 1990.  And this is a list of members of the SDS in Borovo.  And

 6     you can see as number 1 Vukasin Soskocanin as president of the SDS there.

 7             Is this something -- does this help you establish the time-line a

 8     little bit or --

 9        A.   I can see that, yes.  It does help.  That means he was a member

10     earlier without me knowing.  Yes, yes.  It helps me.  I see that it's the

11     12th of November, 1990, but I didn't know that.

12        Q.   Now, when you met with the members of the Defence team here in

13     the last couple of days, they made some notes about what you said about

14     Vukasin Soskocanin.  And one thing which was not put to you this morning,

15     and I would like you to confirm that this is something you said in

16     proofing, was that after the Borovo Selo incident, Soskocanin stated for

17     the media that he personally killed five Ustashas during the battle in

18     Borovo Selo on the 2nd of May, 1991.  Is that accurate, sir?

19        A.   It's accurate.  He made that statement for TV Novi Sad.  That's

20     what he said and there must be some recording kept at Television

21     Novi Sad.  I saw it on TV in the first place.  He was shown on television

22     saying, "I killed five them in battle and I will kill 55 more," in

23     combat, of course.

24        Q.   Sir, if someone is claiming on TV that he killed five person

25     on -- in a battle and he would kill 55 [as interpreted] more, would you

Page 11638

 1     agree that this is quite an extreme position?

 2        A.   Yes.

 3             THE INTERPRETER:  Interpreter's correction:  The other number was

 4     "505," not "55."

 5             THE WITNESS: [Interpretation] Yes, it is.

 6             MR. DEMIRDJIAN:

 7        Q.   Now, I want us to move to the issue of the attack on Dalj which

 8     you talked about this morning.  You mentioned that you were in a group

 9     led by Marko Loncarevic.  Can you tell us how large this group was?

10        A.   Which item?  Which point?

11        Q.   It doesn't matter at this moment, but could you remember

12     independently from the statement how many people were there in this group

13     led by Marko Loncarevic?

14        A.   Five or six.

15        Q.   Okay.  Now you also say that you found out about the attack no

16     more than half an hour prior to the departure.  This is something you

17     said paragraph 14 of your statement.  Do you stand by that statement?

18        A.   Yes.

19        Q.   Okay.  Now you found out no more than half an hour prior to the

20     departure.

21        A.   Yes.

22        Q.   Were you, however, aware that an attack was imminent and that

23     there were some plans in the workings?

24        A.   No.  He told me to come to the hall, and when I arrived, there

25     were already about a hundred people there.  I didn't even know that there

Page 11639

 1     would be an attack.  He just told me to come to the hall and there was

 2     some attack being planned.  He told me that in the hall.

 3        Q.   Now, was there any arming happening prior to the attack in

 4     preparation?

 5        A.   Well, everybody was armed.

 6        Q.   Specifically -- I'm talking about specifically for the attack.

 7     Was there any arming being conducted a day or two days earlier?

 8        A.   Well, everybody had weapons even before.  We were told to come

 9     with our weapons.

10             MR. DEMIRDJIAN:  Can we display 65 ter 6639 at tab 17.

11        Q.   I'm going to show awe document in a moment, Mr. Dafinic.  This is

12     an Official Note.  And just to give you context, it's given by a man by

13     the name of Zdenko Nenic; he lives in Borovo.  Are you familiar with this

14     name?

15        A.   No.

16        Q.   You've never heard of a man named Zdenko Nenic?

17        A.   No, no.

18             MR. DEMIRDJIAN:  If we could move to page 3 in the B/C/S first --

19             THE WITNESS: [Interpretation] Could you please enlarge the text?

20             MR. DEMIRDJIAN:

21        Q.   Yes, just a moment.  I will ask them to enlarge the relevant

22     portion.

23             MR. DEMIRDJIAN:  So this is page 3 in the B/C/S.

24        Q.   It's a very long statement, Mr. Dafinic.  I will show you the

25     relevant portions.

Page 11640

 1             MR. DEMIRDJIAN:  Page 3 in B/C/S is equivalent to page 2 in the

 2     English version.  And I'd like to -- for the B/C/S version, if we could

 3     scroll -- yeah, zoom on the bottom part, please, in the last three

 4     paragraphs.  Yes, exactly.  Thank you very much.

 5        Q.   Now, this man Nenic says here that in June or July 1991

 6     Marko Loncarevic, which is somebody we've spoken about earlier today,

 7     approached him to take over some weapons which he would take to his own

 8     house.

 9             And in the next paragraph, Mr. Nenic says that he agreed to take

10     over the weapons, and following a prior agreement with Loncarevic he went

11     to Jovica Vucenovic's house where they took over at least four wooden

12     military boxes.

13             Now, it is correct to say that Mr. Vucenovic was in the TO in

14     Borovo Selo; is that right, Mr. Dafinic?

15        A.   That's right, yes.

16             MR. DEMIRDJIAN:  Now, if we go to the next page in the English

17     version.

18        Q.   Here it says that, in the top part:

19             "After they had cleaned the weapons, Loncarevic instructed them

20     to take the weapons to the Orthodox church in Borovo and store them in

21     Milenko Dafinic's house which stood in the immediate vicinity of the

22     church.  The interviewee remembers that when they arrived at that

23     location, they did not find Dafinic."

24             MR. DEMIRDJIAN:  If we can go to the next page in the English

25     version and also in the B/C/S version.

Page 11641

 1        Q.   So they did not find Dafinic.

 2             MR. DEMIRDJIAN:  And if we move to the top part of the next page

 3     in the B/C/S.

 4        Q.   "... at home, his wife, Jovanka, nee Blagojevic, and Milenko's

 5     father showed them where to put the weapons.  Talking to Dafinic several

 6     days later, the interviewee learned that the weapons were destined for

 7     Dalj because an attack on that village was being planned."

 8             Now, sir, does that remind you a little bit of the arming that

 9     was taking place at the time?

10        A.   Yes, yes, it does refresh my memory.

11        Q.   And it carries on here to talk about a -- one or two nights ago a

12     meeting which was led by Marko Loncarevic and where several people were

13     gathered in a hall.  Does that also match with your recollection of the

14     events?

15        A.   Let's go back to the first part.  My wife wasn't there at the

16     time, and my father doesn't live in the same house as me so he could not

17     have been there.  So this is not clear to me.  My wife was absent as a

18     displaced person, and my father lives at a different address in a street

19     called Skolska.  So this is entirely unclear to me.

20             As to weapons, yes, there were weapons.  But as to my wife and my

21     father being there, that's impossible.  My father knew absolutely nothing

22     about what I was doing, and the same goes for my wife.  Especially since

23     she wasn't there even.

24        Q.   But do you agree that you did know a couple of days earlier that

25     the attack was being planned?  Do you agree on that part of the

Page 11642

 1     statement?

 2        A.   I agree that the weapons were cleaned and left in my place and in

 3     Jovica Vucenovic's place, but I do not agree as to knowing about when the

 4     attack was going to be carried out.  I did not know it several days in

 5     advance, and I would not have taken the risk of having the weapons

 6     cleaned in my house.  I would not have exposed my family to such a risk.

 7        Q.   Very well.

 8             MR. DEMIRDJIAN:  Your Honours, may I tender this statement, which

 9     was at tab 17, 65 ter number is 6639.

10             JUDGE DELVOIE:  Mr. Zivanovic.

11             MR. ZIVANOVIC:  I would object, because this statement does not

12     fulfil the requirements from Rule 92 ter, bis, or quater to be tendered

13     into evidence.

14             MR. DEMIRDJIAN:  Just to clarify, it's strictly for impeachment

15     purposes, Your Honours, and not for the substance.

16             MR. ZIVANOVIC:  The relevant parts are already read and there is

17     no need to tender this document for the impeachment.

18                           [Trial Chamber confers]

19             JUDGE DELVOIE:  Objection sustained.  We will not admit the

20     document.  Everything is on the record.

21             MR. DEMIRDJIAN:  Thank you, Your Honours.  Much obliged.

22        Q.   Mr. Dafinic, I would like to return to the issue of your group,

23     the government security group.  You mention in your statement that

24     Mr. Zarko Aleksic was involved in theft, and you seem to have focused

25     mainly on his activities in your statement as far as members of your

Page 11643

 1     group are concerned.  Is there any reason why you spoke about Aleksic's

 2     involvement and not the other members of your group?

 3        A.   There is no special reason except I never learned anything about

 4     others.  I simply didn't learn about others.

 5             And as for Aleksic, the facts were there.  It's not that I

 6     focused on him.  I simply told you everything I knew and what I had

 7     heard.  I didn't see it.  I heard that about Stevo Bogic.  I didn't catch

 8     him stealing.  I simply heard that he had done it.  I didn't focus on

 9     him.  I simply told you what I knew.

10        Q.   In terms of catching him stealing, was Mr. Aleksic ever set up?

11     Was there a trap set for him to see if he was stealing?

12        A.   Well, I'm not the one to tell you about that.  Perhaps he was set

13     up.  I simply don't know.  I didn't.  I'm not the right person to answer

14     that question.  I didn't set him up.  And as for others, I don't know.

15        Q.   Now, with respect to others, isn't it true, sir, that

16     Sinisa Gajic and Dragan Lazarevic were involved in stealing money from a

17     bakery in Dalj just following the take-over on the 1st of August of 1991?

18     Is that something you were familiar with at the time?

19        A.   No, no, no.  They were not in my group, not during the assault.

20     I didn't know anything about that.  Really nothing.

21        Q.   Did you find out about it afterwards at a later stage?

22        A.   No.  I sold Sinisa Gajic a small Ferguson tractor and some tools.

23     I did not have anything to live on, so he [as interpreted] sold a

24     tractor, a trailer.  He gave me a certain amount of money which -- with

25     which I bought food for my family who were in exile.  I can't even -- I

Page 11644

 1     could not even dream that he would be participating in the thing that

 2     you're describing.  I thought he had money.  By then, I had all dispensed

 3     all of my money.  In order to be able to survive, I had to start selling

 4     my belongings.

 5             MR. ZIVANOVIC:  Just one correction in the transcript or in

 6     interpretation.  It is line 14.  It is said:

 7             "I did not have anything to live on, so he sold the tractor ..."

 8             The witness said "I sold ..."

 9             MR. DEMIRDJIAN:  Yes.

10             MR. ZIVANOVIC:  "... the tractor."

11             MR. DEMIRDJIAN:  Yes, I agree with that.

12        Q.   Sir, are you familiar with a restaurant in Erdut Planina which at

13     the time was called Saran?

14        A.   No, I did not go there before the war or during the war.  I never

15     went there.  I moved in the direction of Vukovar and Borovo Naselje.

16     Those were our locations.  Perhaps I went to Trpinja and Bogota, but the

17     places you mention in your question, no, I never went there.

18        Q.   No, you never went there but had you heard of it?

19        A.   No.

20        Q.   Did you know that there was a restaurant in Erdut Planina which

21     was owned by a Hungarian man who was known as Ferika, last name Pap.

22        A.   No, I never went to that side.  I went to Okonja's bar.  A good

23     bar.  There were six pubs or bars in Borovo Selo, so I did not have any

24     reason to go elsewhere.  I didn't even go to Dalj.  I went to a totally

25     different side.

Page 11645

 1        Q.   I'm not talking about the time that you were in Borovo Selo.  I'm

 2     talking about the time where you stayed, as you said earlier, in the

 3     government building in Erdut.  Now, Erdut Planina is not very far from

 4     Erdut, is it?

 5        A.   Yes.

 6        Q.   Now during your time there, have you not ever heard about this

 7     restaurant and his owner?  So I'm talking about September 1991 onwards.

 8        A.   I didn't hear anything because I didn't go there.  I didn't have

 9     time.  I had a lot of commitments.  I didn't hear.  I didn't go there.

10        Q.   Sir, we have information that Mr. Pap was brought for

11     interrogation at Arkan's training centre in November of 1991.  Did you

12     know that?

13        A.   No.

14        Q.   Did you know a man by the name of Milorad Stricevic, who was also

15     known as Puki?

16        A.   I used to see him.

17        Q.   And did you know that as part of his work he -- it was charged

18     [sic] of interrogating prisoners?

19        A.   No, no.  No.  He didn't brag about that.  And why would he ever

20     tell me that?  I keep on repeating that I was a guard, and if he was a

21     colonel and if I was a guard, why would he ever confide in me?  Of course

22     no, I didn't hear that.

23        Q.   Sir, Mr. Stricevic interrogated the owner of this restaurant,

24     Mr. Pap, in the training centre, and there are suggestions that you are

25     present during this interrogation and took part in the mistreatment of

Page 11646

 1     this restaurant owner.

 2        A.   First of all, as I've already told you, I did pass by the centre.

 3     And as a foot soldier, as a regular soldier, I did not have access to the

 4     centre, so I never entered it.  The discipline over there was such that

 5     nobody could enter if they were not authorised.

 6        Q.   But if they were invited --

 7        A.   Really nobody.  Nobody.  What?  What?  I don't understand.

 8        Q.   But if they were invited to attend, they could, couldn't they?

 9        A.   If somebody was to invite me?

10        Q.   Sir, let's move on a bit here because it is also suggested that

11     Mr. Pap's --

12        A.   Yes, go ahead.

13        Q.   -- Mr. Pap's wife was looking for him, and this became a bit of a

14     disturbance in Erdut because she kept asking about him.  Were you

15     familiar with the fact that a woman was looking for her disappeared

16     husband?  And we're talking about the period of November 1991.

17        A.   No.  As far as I know, she never approached me when I was on

18     sentry duty.  She never came to our facility.  I don't know about the

19     others, but she never approached me with that request.

20        Q.   Didn't Stevo Bogic order you, Sinisa Gajic, and Zarko Aleksic to

21     go to her house, confiscate money from this woman, and arrest her?

22        A.   No.  I've never heard such thing.  First of all, he was not in a

23     position to give me such an order.  He could not order me to do such

24     things.

25        Q.   Wasn't he your superior?

Page 11647

 1        A.   Yes.  But in terms of securing the government, he was not there

 2     to tell me to arrest people, because he knew I would never do that.  I'm

 3     sure he knew that very well.  Well, I mean, why don't you ask him?  I'm

 4     sure he will tell you that he knows that I would never do that.

 5        Q.   If you are ordered to arrest someone and you have a pass which

 6     allows you to arrest someone, why are you telling us that you would never

 7     arrest someone?

 8        A.   Why wouldn't I arrest people?  And in the ID it said that we were

 9     authorised to bring people in, that we could do that.  But there were no

10     grounds.  I did not have any grounds to do that.  I'm not a police

11     officer.  I'm not an investigative body.  I was not trained to

12     interrogate people.  It was the police that did that.  We were provided

13     with official ID cards to move about freely, not to arrest and bring in

14     people.  I was not qualified for such things.  Professionals, qualified

15     people, trained police officers are -- were supposed to do that and not

16     me.  And I would have never done that.

17        Q.   Sir, are you familiar with a woman who was a cook in the

18     government building's kitchen by the name of Viktorija Albert?

19        A.   There were several cooks but none of their names ring any bells.

20        Q.   Now, this particular cook was in a friendly relation with

21     Mr. Milorad Stricevic.  Did you ever hear that Arkan dismissed Stricevic

22     from his position for protecting Ms. Albert and her family?

23        A.   No, no, no.  That was beyond my rank and beyond my sphere of

24     interest.  I never heard that.

25             I keep on repeating:  Why would anybody be discussing things like

Page 11648

 1     that in front of me?  Again, I don't understand what you're saying.  Why

 2     would Arkan ever say that to me or whoever?  No, I never heard any such

 3     thing.

 4        Q.   I did not suggest that he would have told you, personally.  What

 5     I'm saying here is that it was well known that Mr. Stricevic was

 6     protecting this family and that he was dismissed and that effectively we

 7     know that he was also killed.  Do you know about the circumstances of his

 8     death?

 9        A.   No.  When it comes to Arkan's personnel policy, I was not in a

10     position to know whom he promoted, whom he removed.  There were lot of

11     people there that belonged to him, but I did not have a clue of what was

12     going on, and none of them ever told anything to us.  I suppose that they

13     did not dare say anything to us.  So how would I have obtained such

14     information?  Sometime when they passed by us, they would say, "Hello."

15     Sometimes not even that.  They just frowned upon us.  That was all.

16        Q.   Sir, were you familiar with the fact that Ms. Albert's home,

17     which was very close to the government building, was appropriated and

18     turned into a brothel?  Were you aware of that?

19        A.   No.

20        Q.   Were you familiar with the fact that there was a brothel in Erdut

21     very close to the government building?

22        A.   I heard about that, but it was kept secret from me.

23        Q.   You never went there?

24        A.   No.

25             MR. DEMIRDJIAN:  Your Honours, can we display 65 ter 6638,

Page 11649

 1     please.  Tab 16.

 2        Q.   Sir, what we're looking at here is the statement of a woman named

 3     Katica Dagovic who lives in Borovo.

 4        A.   What's the name?  Katica what?  Dagovic.

 5        Q.   Quite right.  Did you know her?

 6        A.   No.

 7        Q.   She seems to be familiar with you.  And I would like you to look

 8     at -- first of all, at page 1, we see her name.

 9        A.   Perhaps I did know her, but I can't remember her. She doesn't

10     mean anything to me.

11        Q.   Well, she was born on the 21st of June, 1960, so at the time of

12     the events, she was around 21, 22 years old.  And what she describes here

13     is the events in Borovo Selo.

14             MR. DEMIRDJIAN:  And I'd like us to go to page 3 in both the

15     English and the B/C/S version.  In the B/C/S version, we can zoom on

16     the -- well, if you're in the English version, zoom on the bottom part.

17     Thank you.  Now top part in the B/C/S version.

18        Q.   Here she describes about individuals who carried out especially

19     brutal persecution of Croatian population in Borovo Selo itself.  She

20     lists a number of people, including Stevo Bogic, Branko Ciric, you're

21     listed there, so is Mr. David Cesic, and other members of your group.

22             MR. DEMIRDJIAN:  Now if we move to page 4 in the English version.

23     The bottom part of page 4.  The very last paragraph.  And the B/C/S

24     version, we scroll down a little bit.  In fact, we'll need to go to the

25     next page in the B/C/S version.  Top part.  Yeah.  Thank you.

Page 11650

 1        Q.   The paragraph begins with:

 2             "During 1993 ..."

 3             She explains that her husband was mobilised in the JNA, so she

 4     was alone in her house with her two daughters.

 5             "At an unspecified date at around 9.30 at night, someone rang at

 6     the house doorbell.  Milenko Dafinic stood in the doorway dressed in

 7     civilian clothes and told her that he needed to talk to her."

 8             She describes the conversation you had and that you took her in

 9     silence to Erdut to the barracks of Arkan.  At the time she was worried

10     about her children.  And when you arrived to the building in question,

11     she could see that this was a large facility with a lot of rooms.  Next

12     to it there was a coffee bar and a disco which were built up for

13     Arkan's Tigers.  There was also a brothel.  And she got scared.  She

14     describes the brothel here.

15             JUDGE DELVOIE:  Mr. Demirdjian, do we have all this on the

16     document on the screen?

17             MR. DEMIRDJIAN:  Yes, Your Honours.  I'm still at -- in the first

18     paragraph.

19        Q.   And the very last sentence of the paragraph talks about the

20     location of the brothel.

21             JUDGE DELVOIE:  We just change the page.  Okay.

22             MR. DEMIRDJIAN:  I apologise, Your Honours.  Yes, we have to turn

23     the page.

24        Q.   So this was all in the first paragraph, everything that I

25     described, about being taken to Erdut, to Arkan's barracks, and that she

Page 11651

 1     was taken to this brothel, and she got scared.

 2             Now, the next paragraph gives some details about the brothel.

 3     And in the middle of the paragraph it says that, first of all:

 4             "In addition to Arkan, the following men also owned these girls.

 5     David Cesic, Stevo Bogic, Milenko Dafinic, Petar Rakas, and Rujo from

 6     Savulje who were in league with Hadzic."

 7             And in the next paragraph, she says the following:

 8             "After arriving at the building, Milenko Dafinic takes the said

 9     Katica through to his room and tells her to relax and calm down and that

10     in the end she would even be laughing and that if she won't that she

11     would end her career in an Erdut well."

12             The paragraph carries on to describe that Petar Rakas came in and

13     asked you to return her home and that you returned her home and you

14     apologised on the way.

15             Does this statement refresh your memory about, first of all, this

16     woman and that the fact that you arrested her and brought her over to the

17     location she describes?

18        A.   I don't know.  First of all, the Russian who's mentioned here, he

19     was not in my group.  I never socialised with him.  I socialised with

20     Pero Rakas.

21             Why would I take her there?  Why would I apologise to her?  That

22     woman's name really doesn't ring a bell.  Why would I take her there and

23     then return her home?  I don't understand why.  To show her the brothel.

24     Why would I have done that?  This is completely untrue.  I know nothing

25     about that.  This -- I've never heard of that before or seen it before.

Page 11652

 1             That guy, Rujo, and it says Ceca Valiskovic [phoen] was also

 2     brought there.  I don't know.  This is -- I really don't understand.

 3     This is totally beyond any common sense.  I never participated in this.

 4     I'm just reading what I see in front of me.

 5        Q.   Let me stop you for a minute here.  The paragraph that you have

 6     in front of your eyes right now names Mr. David Cesic, Stevo Bogic,

 7     Petar Rakas.  Now these are individuals who are part of your group; isn't

 8     that correct?

 9        A.   Yes, yes.  But Rujo is not from Savulje.  And he says Rujo and

10     Hadzic are in cahoots.  What cahoots?  He was from in our group, but I

11     didn't do that, and I don't believe that any of them did.  But you have

12     to ask them.  I'm sure I didn't.  I can speak for myself.

13        Q.   So you still stand by your statement that you never arrested

14     anyone and brought them over?

15        A.   No, I did not.  And particularly not to Arkan's place.  I told

16     you, there was no way I could enter Arkan's premises, and I didn't.  And

17     Petar Rakas also, Rus [as interpreted], David Cesic.  Stevo Bogic, yes,

18     perhaps.  But the rest of us, we could not enter those premises at all.

19     There was no way.

20        Q.   Sir, are you familiar with the men from Borovo, his name is

21     Dusan Vukovic, he was the son of Father Prako?

22        A.   Excuse me?  Branko?  Did you say Branko?

23        Q.   The man's name is Dusan Vukovic, and he is the son of a man who's

24     name is Father Prako, P-r-a-k-o.

25        A.   I don't know.  Can you jog my memory?  It was 20 years ago.  I

Page 11653

 1     have forgotten some people.  Vukovic.  Hmm.

 2        Q.   This is a man who worked on a raft connecting Borovo Selo to

 3     Serbia.

 4        A.   Yes, now it does ring a bell.  Dusan -- I apologise.  What name

 5     did you say?  What -- what did you say?

 6        Q.   Vukovic.  Vukovic.

 7        A.   If we have the same person in mind, then I know him.  He was the

 8     one who was in charge of the barge on the Danube.  He transported people

 9     across the river; right?

10        Q.   Correct.  Now if we look at a statement that he's given.

11             MR. DEMIRDJIAN:  This is 65 ter 6637 at tab 15.  If we zoom in on

12     the first page in the central part -- well, in the first paragraph to

13     start with.  Thank you.

14        Q.   You can see his details here.  His name, his date of birth, that

15     he resides in Borovo.

16             In the second paragraph, he states that he was mobilised into the

17     civilian protection and that his superior was Ruza Mandic.  And in 1991,

18     he served as an assistant worker on a raft connecting Borovo Selo.

19             MR. DEMIRDJIAN:  Now, if we turn to page 2 in the English version

20     and in the B/C/S version.  The bottom part.  Yes.  And top part in the

21     B/C/S version.

22        Q.   Mr. Vukovic says that he was aware that Branko Ciric, aka

23     Kotsgar [phoen], was the commander of the upper part of the village, and

24     this is Borovo Selo.  And he mentions a number of people in his group.

25     And then he mentions a number of people in Goran Hadzic's group,

Page 11654

 1     including Relja, Milenko Dafinic, David Cesic, Petar Rakas,

 2     Marinac Aleksic, Stevo Bogic.

 3             MR. DEMIRDJIAN:  The next paragraph -- if we could go to the next

 4     page, please.  Top part.

 5        Q.   It says that Mihajlo Ulemek, the man we mentioned earlier today

 6     from Pazova, "committed various crimes in Daljska Planina and that

 7     Dafinic has bragged about Ulemek killing people.  He also bragged about

 8     the systemic rape and orgies taking place at the winery and that

 9     Pero Rakas operated a brothel."

10             Now, sir, it appears that this man has a lot of details about

11     your group, and it appears that your group was deeply involved in

12     criminal difficulties, wasn't it?

13        A.   That's not true.  I don't know why that person stated that.  That

14     person and I were on very friendly terms.  I saw him actually at

15     Branko Ciric's funeral in Sombor.  I would never brag about Ulemek

16     committing crimes.  He was my neighbour.  He was in charge of the ferry.

17     I don't know why he said that.  Maybe he was put under pressure.  Maybe

18     he wanted to protect himself or somebody dictated this to him.  I don't

19     believe that these are his words.  Actually, they are.  But I don't

20     believe that he would have said this.  First of all, even if I'd known

21     things, I would have not bragged about them.  I'm not that kind of a man.

22     But I don't think that this is his statement.  I absolutely cannot

23     believe that.

24        Q.   You cannot believe it, sir, but we just saw two people mentioning

25     your group being involved in criminal activities and the creation of this

Page 11655

 1     brothel, and what I'm going to --

 2        A.   I apologise, I apologise.  I don't know who served in that.  And

 3     how come they knew all that if they were in Borovo Selo?  No, no.  I

 4     don't agree with this.  No.  No way.  I can't believe that he stated

 5     this, or perhaps he did but under duress.

 6        Q.   Sir, you said this morning that you left the region in July of

 7     1997 during the peaceful reintegration.

 8        A.   Yes, yes.

 9        Q.   Up to that point you were living in Erdut; is that right?

10        A.   No, I lived in Borovo Selo.  I did live in Erdut until 1993 or,

11     rather, from 1991 to 1993, but I visited my own home very often.  Every

12     now and then I would come home.  But we spent a lot of nights there as

13     well and then we would go home and stay there for a couple of days and

14     then we would return.

15        Q.   And, sir, you mentioned you left in July 1997.

16     Mr. Slavko Dokmanovic was arrested on the 27th of June, 1997.  Now isn't

17     it correct that this was -- the news of his arrest were publicly known

18     and were all over the news?

19        A.   Yes, I know that.

20        Q.   And, sir, did you leave the region out of fear that you, too,

21     would be arrested?

22        A.   I left like everybody else.  A majority of the people left, so I

23     did too.  I did not want to go on living there.  Not because I was afraid

24     that I would be arrested.

25        Q.   Is it correct that Mr. Stevo Bogic also left the region around

Page 11656

 1     the same time?

 2        A.   He left earlier.  I stayed the longest of all those people.  They

 3     had to leave earlier because their children started school.  At that time

 4     my children were already out of school, so there was no reason for me to

 5     leave as early as they did.

 6        Q.   And were you familiar with the fact that before you left

 7     Mr. Bogic burnt a number of documents relating to the activities of your

 8     group right in front of his house in a metal barrel?

 9        A.   No.  No, no, no.  Neither did he do that in front of my house,

10     nor do I know that.  Why would he do that in front of my house in the

11     centre of the village for everyone to see?  No, he didn't.  If he did

12     that, it must have been farther away.  He did not do it in front of my

13     house.

14        Q.   The translation may have been missed in this one.  I said that he

15     did it in front of his house.  Did you hear about that?

16        A.   No, no, no.  I thought you suggested he did it in front of my

17     house.  They live a lot farther away from me, but I didn't hear about it.

18             MR. DEMIRDJIAN:  Your Honours, this concludes my

19     cross-examination.

20             May I offer to tender the two statements we just saw, 65 ter 6637

21     and 6638.  Again, specifically for the purposes of impeachment.  Now, I

22     know that some portions of it were read into the record.  However, we

23     believe that it would serve the purposes of the Trial Chamber to have

24     these two statements which involve the witness directly into the

25     activities described in there.

Page 11657

 1             JUDGE DELVOIE:  Mr. Zivanovic.

 2             MR. ZIVANOVIC:  I would object, Your Honour. [Microphone not

 3     activated] If it is only for the --

 4             JUDGE DELVOIE:  Microphone, please.

 5             MR. ZIVANOVIC:  I would object if it was for impeachment because

 6     it was already in the transcript, and I don't see any need to tender

 7     these documents into evidence.  There is no foundation for it.

 8                           [Trial Chamber confers]

 9             MR. DEMIRDJIAN:  Your Honours, may I be permitted to put one more

10     thing?

11             JUDGE DELVOIE:  Yes.

12             MR. DEMIRDJIAN:  In terms of the foundation, I believe that we

13     have seen from these two statements that the witnesses are describing the

14     group that the witness has described and which he agrees are members of

15     his group, so I believe that's, from a foundational point of view, we

16     have something really solid in terms of how this is connected to the

17     witness.

18             MR. ZIVANOVIC:  In that case, it is not for the impeachment

19     purpose.

20             MR. DEMIRDJIAN:  No, it's for the foundation.  That's the

21     foundation, of course.

22             JUDGE DELVOIE:  We'll come back to this issue later on.

23             Mr. Zivanovic, do you have anything in redirect?

24             MR. ZIVANOVIC:  Yes, Your Honour.

25             May we see, please, Exhibit 6639.  It is tab 17.  Could you zoom


Page 11658

 1     in, please.  Just first paragraph.

 2                           Re-examination by Mr. Zivanovic:

 3        Q.   [Interpretation] Mr. Dafinic, you can see here the name of the

 4     police officer who wrote this statement.  Do you know that officer?  I

 5     see his name is Tomislav Farkas.

 6        A.   Yes.  I don't know Tomislav Farkas personally, but he once came

 7     to see my mother-in-law in Borovo Selo, my daughter -- my wife's house as

 8     well, and of course that's my house as well, inherited.  And he said that

 9     my wife should come to an interview related to some purported murder that

10     I committed and threw the bodies in a well.  That was a well that I

11     shared with neighbours, including Pap, before the water-supply, the city

12     water-supply approached Borovo Selo.  I first closed it and poured cement

13     over it.  And then later we were building a swimming pool and then I

14     activated it again.

15             Anyway, the police officer threatened my wife that they would be

16     taken into custody, both she and her mother, unless she comes for that

17     interview.  She was scared and then she told me that -- in fact, she

18     wrote to me asking if she could live with me.  I said yes.  After that I

19     received information that my mother-in-law, Ruza Blagojevic, was supposed

20     to come to Borovo Selo because a buyer for her house had been found.  It

21     was to be sold to Zarko Aleksic, nicknamed The Marine.  In fact, the

22     buyer was Zarko Aleksic's brother, and since Zarko Aleksic had bought a

23     house next door, it would be a good idea for me to sell him or, rather,

24     sell his brother that house.

25             That's what I was told.  I told him to come so we can make a

Page 11659

 1     deal.  I would also sell him that house, but I wanted to see him face to

 2     face because I don't believe that he would make that statement if he had

 3     to look me in the eye.

 4        Q.   How long has it been since those threats made by Farkas to your

 5     mother-in-law, and how long was it between that threat and the offer to

 6     sell your house to this Aleksic?

 7             JUDGE DELVOIE:  Yes, Mr. Demirdjian.

 8             MR. DEMIRDJIAN:  Your Honours, this does -- sorry.  This does not

 9     raise from the cross-examination.  The purpose of showing this statement

10     had nothing to do with the man who took this statement.  Counsel is now

11     exploring a completely different topic which has nothing to do with the

12     statement, so this does not arise out of cross-examination.

13             MR. ZIVANOVIC:  It is closely related to the document and about

14     Mr. Farkas and his connections with somebody else who is very irrelevant

15     for -- in this case.

16             MR. DEMIRDJIAN:  And that's exactly the point.  It has nothing to

17     do with what I raised in cross-examination, Your Honours.

18             MR. ZIVANOVIC:  The document was raised and tried to be tendered,

19     and the portion of these documents were also seated into the transcript

20     without the name of the police officer who took this statement that was

21     challenged by the witness.

22             MR. DEMIRDJIAN:  Your Honours, the Rules --

23             MR. ZIVANOVIC:  I think it is very important to assess this.

24             MR. DEMIRDJIAN:  Your Honours, a document can contain a lot of

25     information.  The rules of re-examination is that counsel is limited to

Page 11660

 1     the topics which were raised in cross-examination.

 2             MR. ZIVANOVIC:  I would just say that it is weight -- it is go to

 3     the weight of the credibility of the document, sorry.

 4                           [Trial Chamber confers]

 5             MR. STRINGER:  Mr. President, could I just make a brief remark on

 6     this point, with your leave.

 7             JUDGE DELVOIE:  I'm about to sustain the objection, Mr. Stringer.

 8             MR. STRINGER:  Very well.  I'll save it for next time, because I

 9     think there will be a next time in respect of redirect examination.

10             JUDGE DELVOIE:  Okay.

11             Please move on, Mr. Zivanovic.

12             MR. ZIVANOVIC:  I've finished my redirect, sorry -- thank you.

13             JUDGE DELVOIE:  Thank you very much.

14             Mr. Dafinic, this brings your testimony to an end.  We thank you

15     very much for coming to The Hague to assist the Tribunal.  You're now

16     released as a witness, and we wish you a safe journey home.  The court

17     usher will escort you out of the courtroom.  Thank you.

18             Yes?

19             THE WITNESS: [Interpretation] I wish to thank all of you for

20     giving me a chance to tell the truth, and I hope that truth will prevail.

21     Thank you very much.

22             JUDGE DELVOIE:  You may leave the courtroom, Mr. Dafinic.

23                           [The witness withdrew]

24             JUDGE DELVOIE:  There is one little issue left.

25             On the record, page 55, line 23, where it is written that I said:


Page 11661

 1             "We give the qualification private session as from that point,"

 2     and what I said was: "We will lift the qualification of private session

 3     as from that point."

 4             MR. DEMIRDJIAN:  Your Honours, before we complete for the day,

 5     did you want to hear more about the two statements that we proposed, or

 6     is it something that you were planning to deliberate on at a further

 7     stage?

 8             JUDGE DELVOIE:  We are planning to think it over, Mr. Demirdjian.

 9             MR. DEMIRDJIAN:  Thank you, Your Honours.

10             JUDGE DELVOIE:  Court adjourned for the week.

11                           --- Whereupon the hearing adjourned at 2.00 p.m.,

12                           to be reconvened on Monday, the 22nd day

13                           of September, 2014, at 9.00 a.m.